This publication is available free of charge from: http://dx.doi.org/10.6028/NIST.SP.800-37r1

NIST Special Publication 800-37

Revision 1

 Guide for Applying the Risk 

Management Framework to

Federal Information Systems

A Security Life Cycle Approach

JOINT TASK FORCE

TRANSFORMATION INITIATIVE

 http://dx.doi.org/10.6028/NIST.SP.800-37r1
This publication is available free of charge from: http://dx.doi.org/10.6028/NIST.SP.800-37r1

NIST Special Publication 800-37

Revision 1

Guide for Applying the Risk 

Management Framework to

Federal Information Systems

 A Security Life Cycle Approach

JOINT TASK FORCE

TRANSFORMATION INITIATIVE

Computer Security Division 

Information Technology Laboratory

National Institute of Standards and Technology

http://dx.doi.org/10.6028/NIST.SP.800-37r1

February 2010

INCLUDES UPDATES AS OF 06-05-2014: PAGE IX

U.S. Department of Commerce 

Gary Locke, Secretary

National Institute of Standards and Technology 

Patrick D. Gallagher, Director 
Special Publication 800-37 Guide for Applying the Risk Management Framework to Federal Information Systems

Revision 1 A Security Life Cycle Approach

________________________________________________________________________________________________

Authority

This publication has been developed by NIST to further its statutory responsibilities under the 

Federal Information Security Management Act (FISMA), Public Law (P.L.) 107-347. NIST is 

responsible for developing information security standards and guidelines, including minimum 

requirements for federal information systems, but such standards and guidelines shall not apply to 

national security systems without the express approval of appropriate federal officials exercising 

policy authority over such systems. This guideline is consistent with the requirements of the 

Office of Management and Budget (OMB) Circular A-130, Section 8b(3), Securing Agency 

Information Systems, as analyzed in Circular A-130, Appendix IV: Analysis of Key Sections. 

Supplemental information is provided in Circular A-130, Appendix III, Security of Federal 

Automated Information Resources.

Nothing in this publication should be taken to contradict the standards and guidelines made 

mandatory and binding on federal agencies by the Secretary of Commerce under statutory 

authority. Nor should these guidelines be interpreted as altering or superseding the existing 

authorities of the Secretary of Commerce, Director of the OMB, or any other federal official. 

This publication may be used by nongovernmental organizations on a voluntary basis and is not 

subject to copyright in the United States. Attribution would, however, be appreciated by NIST.

National Institute of Standards and Technology Special Publication 800-37 Revision 1

Natl. Inst. Stand. Technol. Spec. Publ. 800-37 Revision 1, 102 pages (February 2010)

CODEN: NSPUE2

This publication is available free of charge from: http://dx.doi.org/10.6028/NIST.SP.800-37r1

 

 

Comments on this publication may be submitted to:

National Institute of Standards and Technology

Attn: Computer Security Division, Information Technology Laboratory

100 Bureau Drive (Mail Stop 8930) Gaithersburg, MD 20899-8930

Electronic Mail: sec-cert@nist.gov

Certain commercial entities, equipment, or materials may be identified in this document in order 

to describe an experimental procedure or concept adequately. Such identification is not intended 

to imply recommendation or endorsement by NIST, nor is it intended to imply that the entities, 

materials, or equipment are necessarily the best available for the purpose. 

There may be references in this publication to other publications currently under development by 

NIST in accordance with its assigned statutory responsibilities. The information in this publication, 

including concepts, practices, and methodologies, may be used by federal agencies even before 

the completion of such companion publications. Thus, until each publication is completed, current 

requirements, guidelines, and procedures, where they exist, remain operative. For planning and 

transition purposes, federal agencies may wish to closely follow the development of these new 

publications by NIST.

Organizations are encouraged to review draft publications during the designated public comment 

periods and provide feedback to NIST. Computer Security Division publications are available at 

http://csrc.nist.gov/publications.

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Reports on Computer Systems Technology

The Information Technology Laboratory (ITL) at the National Institute of Standards and 

Technology (NIST) promotes the U.S. economy and public welfare by providing technical 

leadership for the Nation’s measurement and standards infrastructure. ITL develops tests, test 

methods, reference data, proof of concept implementations, and technical analyses to advance the 

development and productive use of information technology. ITL’s responsibilities include the 

development of management, administrative, technical, and physical standards and guidelines for 

the cost-effective security and privacy of other than national security-related information in 

federal information systems. The Special Publication 800-series reports on ITL’s research, 

guidelines, and outreach efforts in information system security, and its collaborative activities 

with industry, government, and academic organizations.

Abstract

This publication provides guidelines for applying the Risk Management Framework (RMF) to 

federal information systems. The six-step RMF includes security categorization, security control 

selection, security control implementation, security control assessment, information system 

authorization, and security control monitoring. The RMF promotes the concept of near real-time 

risk management and ongoing information system authorization through the implementation of 

robust continuous monitoring processes, provides senior leaders the necessary information to 

make cost-effective, risk-based decisions with regard to the organizational information systems 

supporting their core missions and business functions, and integrates information security into the 

enterprise architecture and system development life cycle. Applying the RMF within enterprises 

links risk management processes at the information system level to risk management processes at 

the organization level through a risk executive (function) and establishes lines of responsibility 

and accountability for security controls deployed within organizational information systems and 

inherited by those systems (i.e., common controls).

Keywords

Risk management, risk assessment, security authorization, security control, system development 

life cycle, Risk Management Framework, security control assessment, continuous monitoring, 

ongoing authorization, security categorization, security control selection, security plan, security 

assessment report, plan of action and milestones, security authorization package, authorization to 

operate, common control, information system owner/steward, senior information security officer, 

common control provider, authorizing official.

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Compliance with NIST Standards and Guidelines

In accordance with the provisions of FISMA,1 the Secretary of Commerce shall, on the basis of 

standards and guidelines developed by NIST, prescribe standards and guidelines pertaining to 

federal information systems. The Secretary shall make standards compulsory and binding to the 

extent determined necessary by the Secretary to improve the efficiency of operation or security of 

federal information systems. Standards prescribed shall include information security standards 

that provide minimum information security requirements and are otherwise necessary to improve 

the security of federal information and information systems. 

• Federal Information Processing Standards (FIPS) are approved by the Secretary of 

Commerce and issued by NIST in accordance with FISMA. FIPS are compulsory and 

binding for federal agencies.2 FISMA requires that federal agencies comply with these 

standards, and therefore, agencies may not waive their use.

• Special Publications (SPs) are developed and issued by NIST as recommendations and 

guidance documents. For other than national security programs and systems, federal 

agencies must follow those NIST Special Publications mandated in a Federal Information 

Processing Standard. FIPS 200 mandates the use of Special Publication 800-53, as 

amended. In addition, OMB policies (including OMB Reporting Instructions for FISMA 

and Agency Privacy Management) state that for other than national security programs 

and systems, federal agencies must follow certain specific NIST Special Publications.3

• Other security-related publications, including interagency reports (NISTIRs) and ITL 

Bulletins, provide technical and other information about NIST's activities. These 

publications are mandatory only when specified by OMB.

• Compliance schedules for NIST security standards and guidelines are established by

OMB in policies, directives, or memoranda (e.g., annual FISMA Reporting Guidance).

1 The E-Government Act (P.L. 107-347) recognizes the importance of information security to the economic and 

national security interests of the United States. Title III of the E-Government Act, entitled the Federal Information 

Security Management Act (FISMA), emphasizes the need for organizations to develop, document, and implement an 

organization-wide program to provide security for the information systems that support its operations and assets.

2 The term agency is used in this publication in lieu of the more general term organization only in those circumstances 

where its usage is directly related to other source documents such as federal legislation or policy.

3 While federal agencies are required to follow certain specific NIST Special Publications in accordance with OMB 

policy, there is flexibility in how agencies apply the guidance. Federal agencies apply the security concepts and 

principles articulated in the NIST Special Publications in accordance with and in the context of the agency’s missions, 

business functions, and environment of operation. Consequently, the application of NIST guidance by federal agencies 

can result in different security solutions that are equally acceptable, compliant with the guidance, and meet the OMB 

definition of adequate security for federal information systems. Given the high priority of information sharing and 

transparency within the federal government, agencies also consider reciprocity in developing their information security 

solutions. When assessing federal agency compliance with NIST Special Publications, Inspectors General, evaluators, 

auditors, and assessors consider the intent of the security concepts and principles articulated within the specific 

guidance document and how the agency applied the guidance in the context of its mission/business responsibilities, 

operational environment, and unique organizational conditions.

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Acknowledgements

This publication was developed by the Joint Task Force Transformation Initiative Interagency 

Working Group with representatives from the Civil, Defense, and Intelligence Communities in an 

ongoing effort to produce a unified information security framework for the federal government. 

The Project Leader, Ron Ross, from the National Institute of Standards and Technology, wishes 

to acknowledge and thank the senior leadership team from the U.S. Departments of Commerce 

and Defense, the Office of the Director of National Intelligence, the Committee on National 

Security Systems, and the members of the interagency working group whose dedicated efforts 

contributed significantly to the publication. The senior leadership team, working group members, 

and their organizational affiliations include:

U.S. Department of Defense Office of the Director of National Intelligence

Cheryl J. Roby Honorable Priscilla Guthrie

Acting Assistant Secretary of Defense for Networks Intelligence Community

and Information Integration/ Chief Information Officer

DoD Chief Information Officer

Gus Guissanie Sherrill Nicely

Acting Deputy Assistant Secretary of Defense Deputy Intelligence Community

for Cyber, Identity, and Information Assurance Chief Information Officer

Dominic Cussatt Mark J. Morrison

Senior Policy Advisor Deputy Associate Director of National

Intelligence for IC Information Assurance

Roger Caslow

Lead, C&A Transformation

National Institute of Standards and Technology Committee on National Security Systems

Cita M. Furlani Cheryl J. Roby

Director, Information Technology Laboratory Acting Chair, Committee on National Security 

Systems

William C. Barker Eustace D. King

Chief, Computer Security Division CNSS Subcommittee Co-Chair (DoD)

Ron Ross William Hunteman

FISMA Implementation Project Leader CNSS Subcommittee Co-Chair (DoE)

Joint Task Force Transformation Initiative Interagency Working Group

Ron Ross Gary Stoneburner Dominic Cussatt Kelley Dempsey

NIST, JTF Leader Johns Hopkins APL Department of Defense NIST

Marianne Swanson Jennifer Fabius Greene Dorian Pappas Arnold Johnson

NIST MITRE Corporation National Security Agency NIST

Stuart Katzke Peter Williams Peter Gouldmann Christian Enloe

Booz Allen Hamilton Booz Allen Hamilton Department of State NIST

In addition to the above acknowledgments, a special note of thanks goes to Peggy Himes and 

Elizabeth Lennon for their superb technical editing and administrative support. The authors also 

wish to recognize Beckie Bolton, Marshall Abrams, John Gilligan, Richard Graubart, Esten 

Porter, Karen Quigg, George Rogers, John Streufert, and Glenda Turner for their exceptional 

contributions in helping to improve the content of the publication. And finally, the authors 

gratefully acknowledge and appreciate the significant contributions from individuals and 

organizations in the public and private sectors, nationally and internationally, whose thoughtful 

and constructive comments improved the overall quality and usefulness of this publication.

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DEVELOPING COMMON INFORMATION SECURITY FOUNDATIONS

COLLABORATION AMONG PUBLIC AND PRIVATE SECTOR ENTITIES

In developing standards and guidelines required by FISMA, NIST consults with other federal 

agencies and the private sector to improve information security, avoid unnecessary and costly 

duplication of effort, and ensure that its publications are complementary with the standards and 

guidelines employed for the protection of national security systems. In addition to a comprehensive 

public review and vetting process, NIST is collaborating with the Office of the Director of National 

Intelligence (ODNI), the Department of Defense (DoD), and the Committee on National Security 

Systems (CNSS) to establish a unified information security framework for the federal government. 

A common foundation for information security will provide the Civil, Defense, and Intelligence 

sectors of the federal government and their contractors, more cost-effective and consistent ways to 

manage information security-related risk to organizational operations and assets, individuals, other 

organizations, and the Nation. The unified framework will also provide a strong basis for reciprocal 

acceptance of authorization decisions and facilitate information sharing. NIST is also working with 

many public and private sector entities to establish mappings and relationships between the security 

standards and guidelines developed by NIST and the International Organization for Standardization

and International Electrotechnical Commission (ISO/IEC).

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Table of Contents

CHAPTER ONE INTRODUCTION ..........................................................................................1

1.1 BACKGROUND ........................................................................................................................ 1

1.2 PURPOSE AND APPLICABILITY .................................................................................................. 2

1.3 TARGET AUDIENCE.................................................................................................................. 3

1.4 ORGANIZATION OF THIS SPECIAL PUBLICATION.......................................................................... 4

CHAPTER TWO THE FUNDAMENTALS..................................................................................5

2.1 INTEGRATED ORGANIZATION-WIDE RISK MANAGEMENT.............................................................. 5

2.2 SYSTEM DEVELOPMENT LIFE CYCLE ......................................................................................... 9

2.3 INFORMATION SYSTEM BOUNDARIES ...................................................................................... 10

2.4 SECURITY CONTROL ALLOCATION .......................................................................................... 16

CHAPTER THREE THE PROCESS ......................................................................................18

3.1 RMF STEP 1 – CATEGORIZE INFORMATION SYSTEM ................................................................. 21

3.2 RMF STEP 2 – SELECT SECURITY CONTROLS .......................................................................... 24

3.3 RMF STEP 3 – IMPLEMENT SECURITY CONTROLS..................................................................... 28

3.4 RMF STEP 4 – ASSESS SECURITY CONTROLS.......................................................................... 30

3.5 RMF STEP 5 – AUTHORIZE INFORMATION SYSTEM ................................................................... 34

3.6 RMF STEP 6 – MONITOR SECURITY CONTROLS........................................................................ 38

APPENDIX A REFERENCES............................................................................................A-1

APPENDIX B GLOSSARY................................................................................................B-1

APPENDIX C ACRONYMS ...............................................................................................C-1

APPENDIX D ROLES AND RESPONSIBILITIES....................................................................D-1

APPENDIX E SUMMARY OF RMF TASKS...........................................................................E-1

APPENDIX F SECURITY AUTHORIZATION ......................................................................... F-1

APPENDIX G CONTINUOUS MONITORING.........................................................................G-1

APPENDIX H OPERATIONAL SCENARIOS..........................................................................H-1

APPENDIX I SECURITY CONTROLS IN EXTERNAL ENVIRONMENTS.......................................I-1

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Prologue

“...Through the process of risk management, leaders must consider risk to US interests from 

adversaries using cyberspace to their advantage and from our own efforts to employ the global 

nature of cyberspace to achieve objectives in military, intelligence, and business operations... “

 “...For operational plans development, the combination of threats, vulnerabilities, and impacts 

must be evaluated in order to identify important trends and decide where effort should be applied 

to eliminate or reduce threat capabilities; eliminate or reduce vulnerabilities; and assess,

coordinate, and deconflict all cyberspace operations...”

“...Leaders at all levels are accountable for ensuring readiness and security to the same degree 

as in any other domain..."

-- THE NATIONAL STRATEGY FOR CYBERSPACE OPERATIONS 

 OFFICE OF THE CHAIRMAN, JOINT CHIEFS OF STAFF, U.S. DEPARTMENT OF DEFENSE

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Errata

The following changes have been incorporated into Special Publication 800-37, Revision 1. 

Errata updates include corrections, clarifications, or other minor changes in the publication that 

are either editorial or substantive in nature.

DATE TYPE CHANGE PAGE

06-05-2014 Substantive Added Abstract Section. iii

06-05-2014 Substantive Added Keywords Section. iii

06-05-2014 Substantive

Added “The information system owner and information owner/steward consider 

results from the initial risk assessment as a part of the security categorization 

decision. The security categorization decision is consistent with the organization’s 

risk management strategy to identify potential impact to mission/business functions 

resulting from the loss of confidentiality, integrity, and/or availability.” to Task 1-1, 

Supplemental Guidance.

21

06-05-2014 Editorial

Moved “The results of the security categorization process influence the selection of 

appropriate security controls for the information system and also, where applicable, 

the minimum assurance requirements for that system.” to the beginning of new 

paragraph 2, Task 1-1, Supplemental Guidance.

21

06-05-2014 Substantive Changed “executive (function)” to “management strategy” in Task 1-1, 

Supplemental Guidance. 21

06-05-2014 Substantive Deleted “concerning the risk management strategy for the organization” from Task 

1-1, Supplemental Guidance. 21

06-05-2014 Editorial

Moved “The organization may consider decomposing the information system... into 

multiple subsystems to more efficiently and effectively allocate security controls to 

the system. One approach is to categorize each identified subsystem (including 

dynamic subsystems). Separately categorizing each subsystem does not change 

the overall categorization of the information system. Rather, it allows the 

constituent subsystems to receive a separate allocation of security controls from 

NIST Special Publication 800-53 instead of deploying higher-impact controls across 

every subsystem. Another approach is to bundle smaller subsystems into larger 

subsystems within the information system, categorize each of the aggregated 

subsystems, and allocate security controls to the subsystems, as appropriate. 

Security categorization information is documented in the system identification 

section of the security plan or included as an attachment to the plan.” to end of 

Task 1-1, Supplemental Guidance.

21

06-05-2014 Substantive Added “(informed by the initial risk assessment)” to Milestone Checkpoint #1. 23

06-05-2014 Substantive

Deleted “The security control selection process includes, as appropriate: (i) 

choosing a set of baseline security controls; (ii) tailoring the baseline security 

controls by applying scoping, parameterization, and compensating control 

guidance; (iii) supplementing the tailored baseline security controls, if necessary, 

with additional controls and/or control enhancements to address unique 

organizational needs based on a risk assessment (either formal or informal) and 

local conditions including environment of operation, organization-specific security 

requirements, specific threat information, cost-benefit analyses, or special 

circumstances; and (iv) specifying minimum assurance requirements, as 

appropriate. Organizations document in the security plan, the decisions (e.g., 

tailoring, supplementation, etc.) taken during the security control selection process, 

providing a sound rationale for those decisions.” from Task 2-2, Supplemental

Guidance, paragraph 1.

25

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DATE TYPE CHANGE PAGE

06-05-2014 Substantive

Added “After selecting the applicable security control baseline, organizations apply 

the tailoring process to align the controls more closely with the specific conditions 

within the organization (i.e., conditions related to organizational risk tolerance, 

missions/business functions, information systems, or environments of operation). 

The tailoring process includes: (i) identifying and designating common controls in 

initial security control baselines; (ii) applying scoping considerations to the 

remaining baseline security controls; (iii) selecting compensating security controls, 

if needed; (iv) assigning specific values to organization-defined security control 

parameters via explicit assignment and selection statements; (v) supplementing 

baselines with additional security controls and control enhancements, if needed; 

and (vi) providing additional specification information for control implementation, if 

needed. Organizations use risk assessments to inform and guide the tailoring 

process for organizational information systems and environments of operation. 

Threat data from risk assessments provide critical information on adversary 

capabilities, intent, and targeting that may affect organizational decisions regarding 

the selection of additional security controls, including the associated costs and 

benefits. Risk assessment results are also leveraged when identifying common 

controls to help determine if such controls available for inheritance meet the 

security requirements for the system and its environment of operation (including 

analyses for potential single points of failure).” to Task 2-2, Supplemental 

Guidance, paragraph 1.

25

06-05-2014 Substantive Deleted “selected” from item (iii) in Task 2-3, Supplemental Guidance. 26

06-05-2014 Substantive Deleted “selecting security controls to be monitored post deployment and for” from

Task 2-3, Supplemental Guidance, paragraph 2. 26

06-05-2014 Substantive Changed “of such monitoring” to “with which security controls are monitored post 

deployment” in Task 2-3, Supplemental Guidance, paragraph 2. 26

06-05-2014 Substantive Changed “selection” to “frequency” in Task 2-3, Supplemental Guidance, paragraph 

2. 26

06-05-2014 Substantive

Changed “are assessed as frequently as necessary consistent with the criticality of 

the function and capability of the monitoring tools” to “may require more frequent 

assessment” in Task 2-3, Supplemental Guidance, paragraph 2.

26

06-05-2014 Substantive Deleted “selection of specific security controls to be monitored and the” from Task 

2-3, Supplemental Guidance, paragraph 3. 26

06-05-2014 Substantive Deleted “such” from Task 2-3, Supplemental Guidance, paragraph 3. 26

06-05-2014 Substantive

Added “NIST Special Publication 800-137 provides additional guidance on 

continuous monitoring and continuous monitoring strategies.” to Task 2-3, 

Supplemental Guidance, paragraph 4.

26

06-05-2014 Editorial Changed “;” to “,” after 800-53 in Task 2-3, References. 26

06-05-2014 Substantive Added “800-137” to Task 2-3, References. 26

06-05-2014 Substantive Deleted “and supplemented” from Milestone Checkpoint #2. 27

06-05-2014 Substantive

Added “Early integration of information security requirements into the system 

development life cycle is the most cost-effective method for implementing the 

organizational risk management strategy at Tier 3.” to Task 3-1, Supplemental 

Guidance, paragraph 1.

28

06-05-2014 Substantive

Added “Risk assessment may help inform decisions regarding the cost, benefit, 

and risk trade-offs in using one type of technology versus another for control 

implementation.” to Task 3-1, Supplemental Guidance, paragraph 1.

28

06-05-2014 Substantive

Added “Risk assessment may help determine how gaps in protection needs 

between systems and common controls affect the overall risk associated with the 

system, and how to prioritize the need for compensating or supplementary controls 

to mitigate specific risks.” to Task 3-1, Supplemental Guidance, paragraph 2.

28

06-05-2014 Editorial Change “make” to “support” in Task 4-1, Supplemental Guidance, paragraph 2. 30

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DATE TYPE CHANGE PAGE

06-05-2014 Substantive

Added “or that are discovered post-development. Such weaknesses and 

deficiencies are potential vulnerabilities if exploitable by a threat source.” to Task 4-

4, Supplemental Guidance, paragraph 1.

32

06-05-2014 Substantive Added “provide important information that” to Task 4-4, Supplemental Guidance, 

paragraph 1. 32

06-05-2014 Editorial Change “facilitate” to “facilitates” in Task 4-4, Supplemental Guidance, paragraph 

1. 32

06-05-2014 Substantive Added “, based on an initial or updated assessment of risk,” to Task 4-4, 

Supplemental Guidance, paragraph 1. 32

06-05-2014 Editorial

Moved “An updated assessment of risk (either formal or informal) based on the 

results of the findings produced during the security control assessment and any 

inputs from the risk executive (function), helps to determine the initial remediation 

actions and the prioritization of such actions.” in Task 4-4, Supplemental Guidance, 

paragraph 1.

32

06-05-2014 Substantive Added “the security control assessor reassesses” to Task 4-4, Supplemental 

Guidance, paragraph 1. 33

06-05-2014 Substantive Deleted “are reassessed” from Task 4-4, Supplemental Guidance, paragraph 1. 33

06-05-2014 Substantive

Added “Did the assessor reassess the remediated controls for effectiveness to 

provide the authorization official with an unbiased, factual security assessment 

report on the weaknesses or deficiencies in the system?” to Milestone Checkpoint 

#4?

33

06-05-2014 Substantive Changed “mitigation” to “response” in Task 5-3, Supplemental Guidance,

paragraph 1. 35

06-05-2014 Substantive

Added “After risk determination, organizations can respond to risk in a variety of 

ways, including: (i) accepting risk; (ii) avoiding risk; (iii) mitigating risk; (iv) sharing 

risk; (v) transferring risk; or (vi) a combination of the above. Decisions on the most 

appropriate course of action for risk response include some form of prioritization. 

Some risks may be of greater concern than other risks. In that case, more 

resources may need to be directed at addressing higher-priority risks than at other 

lower-priority risks. This does not necessarily mean that the lower-priority risks are 

ignored. Rather, it could mean that fewer resources are directed at the lowerpriority risks (at least initially), or that the lower-priority risks are addressed at a 

later time. A key part of the risk decision process is the recognition that regardless 

of the risk decision, there typically remains a degree of residual risk. Organizations 

determine acceptable degrees of residual risk based on organizational risk 

tolerance.” to Task 5-3, Supplemental Guidance, paragraph 1.

35

06-05-2014 Editorial

Moved “Authorization termination dates are influenced by federal and/or 

organizational policies which may establish maximum authorization periods.” to 

second paragraph in Task 5-4, Supplemental Guidance.

36

06-05-2014 Substantive

Deleted “For example, if the maximum authorization period for an information 

system is three years, then an organization establishes a continuous monitoring 

strategy for assessing a subset of the security controls employed within and 

inherited by the system during the authorization period. This strategy allows all 

security controls designated in the respective security plans to be assessed at least 

one time by the end of the three-year period. This also includes any common 

controls deployed external to organizational information systems.” from Task 5-4, 

Supplemental Guidance, paragraph 3.

36

06-05-2014 Substantive

Added “As risk assessments are updated and refined, organizations use the results 

to modify security plans based on the most recent threat and vulnerability 

information available. Updated risk assessments provide a foundation for 

prioritizing/planning risk responses.” to Task 6-1, Supplemental Guidance, 

paragraph 2.

38

06-05-2014 Substantive Deleted “a selected subset of” from Task 6-2. 38

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DATE TYPE CHANGE PAGE

06-05-2014 Substantive

Deleted “Organizations assess all security controls employed within and inherited 

by the information system during the initial security authorization.” from Task 6-2, 

Supplemental Guidance.

39

06-05-2014 Editorial Added “(i.e., during continuous monitoring)” after “initial authorization” to Task 6-2, 

Supplemental Guidance. 39

06-05-2014 Substantive Changed “a subset of the” to “all” in Task 6-2, Supplemental Guidance. 39

06-05-2014 Substantive Added “employed within and inherited by the information system” to Task 6-2, 

Supplemental Guidance. 39

06-05-2014 Editorial Deleted “during continuous monitoring” after “on an ongoing basis” from Task 6-2, 

Supplemental Guidance. 39

06-05-2014 Substantive Deleted “selection of appropriate security controls to monitor and the” from Task 6-

2, Supplemental Guidance. 39

06-05-2014 Editorial Changed “are” to “is” in Task 6-2, Supplemental Guidance. 39

06-05-2014 Substantive Added “in support of ongoing authorization and” to Task 6-2, Supplemental 

Guidance. 39

06-05-2014 Substantive Added “800-137” to Task 6-2, References. 39

06-05-2014 Editorial Changed “Publication” to “Publications” in Task 6-2, References. 39

06-05-2014 Editorial Changed “Decommissioning” to “Disposal” in Task 6-7, Title. 41

06-05-2014 Editorial Changed “decommissioning” to “disposal” in Task 6-7. 41

06-05-2014 Editorial Changed “decommissioning” to “disposal” in Task 6-7, Supplemental Guidance, 

two instances. 41

06-05-2014 Substantive

Added “National Institute of Standards and Technology Special Publication 800-

128, Guide for Security-Focused Configuration Management of Information 

Systems, August 2011.” to Appendix A, References.

A-2

06-05-2014 Substantive

Added “National Institute of Standards and Technology Special Publication 800-

137, Information Security Continuous Monitoring for Federal Information Systems 

and Organizations, September 2011.” to Appendix A, References.

A-2

06-05-2014 Editorial Added definition of “Continuous Monitoring” to Appendix B, Glossary. B-3

06-05-2014 Editorial Added definition of “Risk Assessor” to Appendix B, Glossary. B-8

06-05-2014 Substantive Added “and control enhancements” to Appendix D, Section D.13, paragraph 1. D-7

06-05-2014 Substantive Deleted “a selected subset of” from Appendix E, Task 6-2. E-4

06-05-2014 Editorial Changed “Decommissioning” to “Disposal” in Appendix E, Task 6-7, Title. E-5

06-05-2014 Editorial Changed “decommissioning” to “disposal” in Appendix E, Task 6-7. E-5

06-05-2014 Substantive

Added “Organizations provide an official designation (including any approvals 

required) for information systems that have transitioned from initial authorization to 

operate into an ongoing authorization approach.” to Appendix F, Section F.4, 

paragraph 1.

F-6

06-05-2014 Substantive Changed “adequately mitigate;” to “effectively respond to” in Appendix F, Section 

F.4, paragraph 2. F-6

06-05-2014 Editorial

Moved “Formal reauthorization actions occur at the discretion of the authorizing 

official in accordance with federal or organizational policy.” from Appendix F, 

Section F.4, paragraph 2 to new Section F.5, Reauthorization, paragraph 1.

F-6

06-05-2014 Substantive

Deleted “If a formal reauthorization action is required, organizations maximize the 

use of security and risk-related information produced during the continuous 

monitoring and ongoing authorization processes currently in effect.” from Appendix 

F, Section F.4, paragraph 2.

F-6

06-05-2014 Substantive

Added “NIST Special Publication 800-137 provides additional guidance for 

Information Security Continuous Monitoring Programs.” to Appendix F, Section F.4, 

footnote 71.

F-6

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DATE TYPE CHANGE PAGE

06-05-2014 Substantive

Deleted “Unless otherwise handled by continuous monitoring and ongoing 

authorization, event-driven reauthorizations can occur when there is a significant 

change to an information system or its environment of operation.” from Appendix F, 

Section F.4, paragraph 4.

F-7

06-05-2014 Substantive

Added “When an information system is under ongoing authorization, the system 

may be authorized for ongoing operation on a time-driven or event-driven basis, 

leveraging the security-related information generated by the continuous monitoring 

program. The system is reviewed and authorized for ongoing operation on a timedriven basis in accordance with the authorization frequency determined as part of 

the continuous monitoring strategy. The system is reviewed and authorized for 

ongoing operation on an event-driven basis when pre-defined (trigger) events occur 

or at the discretion of the authorizing official. Whether the authorization for ongoing 

operation is time-driven or event-driven, the authorizing official acknowledges 

ongoing acceptance of identified risks. The organization determines the level of 

formality required for such acknowledgement by the authorizing official.” to 

Appendix F, Section F.4, paragraph 3.

F-7

06-05-2014 Editorial Added new Section F.5, Reauthorization, to Appendix F. F-7

06-05-2014 Substantive

Added “If a formal reauthorization action is required, organizations maximize the 

use of security and risk-related information produced as part of the continuous 

monitoring processes currently in effect.” to Appendix F, new Section F.5, 

paragraph 1.

F-7

06-05-2014 Editorial Changed “Reauthorization actions” to “Formal reauthorization actions” in Appendix 

F, new Section F.5, paragraph 1. F-7

06-05-2014 Substantive Added “(if one is specified)” to Appendix F, new Section F.5, paragraph 1. F-7

06-05-2014 Substantive

Added “If the information system is under ongoing authorization (i.e., a continuous 

monitoring program is in place that monitors all implemented common, hybrid, and 

system-specific controls with the frequency specified in the continuous monitoring 

strategy), time-driven reauthorizations may not be necessary. However, if the 

continuous monitoring program is not yet comprehensive enough to fully support 

ongoing authorization, a maximum authorization period can be specified by the 

authorizing official.” to Appendix F, new Section F.5, paragraph 1.

F-7

06-05-2014 Substantive

Added “For security control assessments associated with reauthorization, 

organizations leverage security-related information generated by the existing 

continuous monitoring program and fill in any gaps with manual or procedural 

assessments. Organizations may also supplement automatically-generated 

information with manually/procedurally-generated assessment information in 

situations where greater assurance is needed.” to Appendix F, new Section F.5, 

paragraph 2.

F-7

06-05-2014 Substantive

Deleted “For example, if the maximum authorization period for an information 

system is three years, then an organization establishes a continuous monitoring 

strategy for assessing a subset of the security controls employed within and 

inherited by the system during the authorization period. This strategy allows all 

security controls designated in the respective security plans to be assessed at least 

one time by the end of the three-year period. This also includes any common 

controls deployed external to organizational information systems.” from Appendix 

F, new Section F.5, paragraph 2.

F-7

06-05-2014 Substantive Deleted “thus supporting the concept of ongoing authorization” from Appendix F, 

new Section F.5, paragraph 2. F-7

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DATE TYPE CHANGE PAGE

06-05-2014 Editorial

Moved “In the event that there is a change in authorizing officials, the new 

authorizing official reviews the current authorization decision document, 

authorization package, and any updated documents created as a result of the 

ongoing monitoring activities. If the new authorizing official is willing to accept the 

currently documented risk, then the official signs a new authorization decision 

document, thus formally transferring responsibility and accountability for the 

information system or the common controls inherited by organizational information 

systems and explicitly accepting the risk to organizational operations and assets, 

individuals, other organizations, and the Nation. If the new authorizing official is not 

willing to accept the previous authorization results (including identified level of risk), 

a reauthorization action may need to be initiated or the new authorizing official may 

instead establish new terms and conditions for continuing the original authorization, 

but not extend the original authorization termination date. In all situations where 

there is a decision to reauthorize an information system or the common controls 

inherited by organizational information systems, the maximum reuse of 

authorization information is strongly encouraged to minimize the time and expense 

associated with the reauthorization effort.” from Appendix F, Section F.4, paragraph 

5 to new Section F.5, paragraph 3.

F-7

06-05-2014 Editorial Added new Section F.6, Event-Driven Triggers, to Appendix F. F-8

06-05-2014 Substantive

Added “Organizations may define event-driven triggers (i.e., indicators and/or 

prompts that cause a pre-defined organizational reaction) for both ongoing 

authorization and reauthorization. Event-driven triggers include, but are not limited 

to: (i) new threat/vulnerability/impact information; (ii) an increased number of 

findings, weaknesses, and/or deficiencies from the continuous monitoring program; 

(iii) new missions/business requirements; (iv) a change in the Authorizing Official; 

(v) a significant change in risk assessment findings; (vi) significant changes to the 

information system, common controls, or the environment of operation; or (vii) 

organizational thresholds being exceeded.” to Appendix F, new Section F.6.

F-8

06-05-2014 Editorial Changed “F.5” to “F.7” in Appendix F. F-8

06-05-2014 Editorial Changed “F.6” to “F.8” in Appendix F. F-9

06-05-2014 Substantive

Deleted “Continuous monitoring is a proven technique to address the security 

impacts on an information system resulting from changes to the hardware, 

software, firmware, or operational environment.” from Appendix G, paragraph 1.

G-1

06-05-2014 Substantive

Added “The following sections provide a general overview of some fundamental 

concepts associated with continuous monitoring. NIST Special Publication 800-137 

provides additional guidance on the development and implementation of 

information security continuous monitoring programs.” to Appendix G, paragraph 1.

G-1

06-05-2014 Substantive

Deleted “including the potential need to change or supplement the control set, 

taking into account any proposed/actual changes to the information system or its 

environment of operation” from Appendix G, Section G.1, paragraph 1.

G-1

06-05-2014 Editorial Changed “will require” to “requires” in Appendix G, Section G.1, paragraph 3. G-2

06-05-2014 Substantive

Changed “Configuration management and control processes for organizational 

information systems” to “Defining a continuous monitoring strategy based on risk 

tolerance that maintains clear visibility into assets, awareness of vulnerabilities, upto-date threat information, and mission/business impacts” in Appendix G, Section 

G.1, paragraph 4.

G-2

06-05-2014 Substantive

Changed “Security impact analyses on proposed or actual changes to 

organizational information systems and environments of operation” to “Establishing 

and implementing a continuous monitoring program that includes monitoring all 

implemented controls at the organization-defined frequency” in Appendix G, 

Section G.1, paragraph 4.

G-2

06-05-2014 Editorial Moved footnote 84 marking to first sentence in Appendix G, Section G.1, paragraph 

4; deleted “)” from footnote 84. G-2

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06-05-2014 Editorial Moved footnote 85 marking from third bullet to second bullet in Appendix G, 

Section G.1, paragraph 4. G-2

06-05-2014 Substantive

Changed “Assessment of selected security controls (including system-specific, 

hybrid, and common controls) based on the organization-defined continuous 

monitoring strategy” to “Analyzing and reporting findings to appropriate 

organizational officials” in Appendix G, Section G.1, paragraph 4.

G-2

06-05-2014 Editorial Moved footnote 86 marking from fourth bullet to third bullet in Appendix G, Section 

G.1, paragraph 4. G-2

06-05-2014 Substantive

Changed “Security status reporting to appropriate organizational officials” to 

“Responding to findings with mitigation, acceptance, transference/sharing, or 

avoidance/rejection” in Appendix G, Section G.1, paragraph 4.

G-2

06-05-2014 Substantive

Changed “Active involvement by authorizing officials in the ongoing management of 

information system-related security risks” to “Reviewing and updating the 

continuous monitoring strategy and program to increase visibility into assets and 

awareness of vulnerabilities” in Appendix G, Section G.1, paragraph 4.

G-2

06-05-2014 Substantive

Deleted “With regard to configuration management and control, it is important to 

document the proposed or actual changes to the information system and its 

environment of operation and to subsequently determine the impact of those 

proposed or actual changes on the overall security state of the system. Information 

systems and the environments in which those systems operate are typically in a 

constant state of change (e.g., upgrading hardware, software, or firmware; 

redefining the missions and business processes of the organization; discovering 

new threats). Documenting information system changes as part of routine SDLC 

processes and assessing the potential impact those changes may have on the 

security state of the system is an essential aspect of continuous monitoring, 

maintaining the current authorization, and supporting a decision for reauthorization 

when appropriate.” from Appendix G, Section G.1, paragraph 5.

G-2

06-05-2014 Substantive

Added “Continuous monitoring is a tactic in a larger strategy of organization-wide 

risk management. Organizations increase situational awareness through enhanced 

monitoring capabilities and subsequently increase insight into and control of the 

processes used to manage organizational security.” to Appendix G, Section G.1, 

paragraph 5.

G-2

06-05-2014 Substantive Changed “Selection of Security Controls for Monitoring” to “Frequency of Security 

Control Monitoring” in Appendix G, Section G.2, Title. G-2

06-05-2014 Substantive Deleted “selecting which security controls to monitor and for” from Appendix G, 

Section G.2, paragraph 1. G-2

06-05-2014 Editorial Changed “such” to “security control” in Appendix G, Section G.2, paragraph 1. G-2

06-05-2014 Editorial Changed “are” to “is” in Appendix G, Section G.2, paragraph 1. G-2

06-05-2014 Editorial Changed “reflect” to “reflects” in Appendix G, Section G.2, paragraph 1. G-2

06-05-2014 Substantive Changed “selection” to “frequency” in Appendix G, Section G.2, paragraph 1, two 

instances. G-2

06-05-2014 Substantive Changed “controls to be monitored and the frequency of the monitoring process” to 

“control monitoring” in Appendix G, Section G.2, paragraph 1. G-2

06-05-2014 Substantive

Deleted “Priority for security control monitoring is given to the controls that have the 

greatest volatility and the controls that have been identified in the organization’s 

plan of action and milestones.” from Appendix G, Section G.2, paragraph 2.

G-3

06-05-2014 Substantive

Added “While a comprehensive discussion of considerations for determining 

monitoring frequencies is provided in NIST Special Publication 800-137, it is 

important to note that security controls that have the greatest volatility and the 

controls that have been identified in the organization’s plan of action and 

milestones are typically monitored more frequently.” to Appendix G, Section G.2, 

paragraph 2.

G-3

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DATE TYPE CHANGE PAGE

06-05-2014 Editorial Deleted “, therefore,” from Appendix G, Section G.2, paragraph 2. G-3

06-05-2014 Substantive Added “and therefore, require more frequent monitoring” to Appendix G, Section 

G.2, paragraph 2. G-3

06-05-2014 Substantive Added “Such controls may also require more frequent monitoring.” to Appendix G, 

Section G.2, paragraph 2. G-3

06-05-2014 Substantive

Deleted “Organizations also consider specific threat information including known 

attack vectors (i.e., specific vulnerabilities exploited by threat sources) when 

selecting the set of security controls to monitor and the frequency of such 

monitoring.” from Appendix G, Section G.2, paragraph 2.

G-3

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CHAPTER ONE

INTRODUCTION

THE NEED FOR INFORMATION SECURITY AND MANAGING RISK

rganizations4 depend on information technology and the information systems5 that are 

developed from that technology to successfully carry out their missions and business 

functions. Information systems can include as constituent components, a range of diverse 

computing platforms from high-end supercomputers to personal digital assistants and cellular 

telephones. Information systems can also include very specialized systems and devices (e.g., 

telecommunications systems, industrial/process control systems, testing and calibration devices, 

weapons systems, command and control systems, and environmental control systems). Federal 

information and information systems6 are subject to serious threats that can have adverse impacts 

on organizational operations (including mission, functions, image, and reputation), organizational 

assets, individuals, other organizations, and the Nation7 by compromising the confidentiality, 

integrity, or availability of information being processed, stored, or transmitted by those systems. 

Threats to information and information systems include environmental disruptions, human or 

machine errors, and purposeful attacks. Cyber attacks on information systems today are often 

aggressive, disciplined, well-organized, well-funded, and in a growing number of documented 

cases, very sophisticated. Successful attacks on public and private sector information systems can 

result in serious or grave damage to the national and economic security interests of the United 

States. Given the significant and growing danger of these threats, it is imperative that leaders at 

all levels of an organization understand their responsibilities for achieving adequate information 

security and for managing information system-related security risks.8

1.1 BACKGROUND

NIST in partnership with the Department of Defense (DoD), the Office of the Director of 

National Intelligence (ODNI), and the Committee on National Security Systems (CNSS), has 

developed a common information security framework for the federal government and its 

contractors. The intent of this common framework is to improve information security, strengthen 

risk management processes, and encourage reciprocity among federal agencies. This publication, 

developed by the Joint Task Force Transformation Initiative Working Group, transforms the 

traditional Certification and Accreditation (C&A) process into the six-step Risk Management 

Framework (RMF). The revised process emphasizes: (i) building information security capabilities 

into federal information systems through the application of state-of-the-practice management, 

operational, and technical security controls; (ii) maintaining awareness of the security state of 

information systems on an ongoing basis though enhanced monitoring processes; and (iii) 

4 The term organization is used in this publication to describe an entity of any size, complexity, or positioning within 

an organizational structure (e.g., a federal agency or, as appropriate, any of its operational elements).

5 An information system is a discrete set of information resources organized for the collection, processing, maintenance, 

use, sharing, dissemination, or disposition of information.

6 A federal information system is an information system used or operated by an executive agency, by a contractor of an 

executive agency, or by another organization on behalf of an executive agency.

7 Adverse impacts to the Nation include, for example, compromises to information systems that support critical 

infrastructure applications or are paramount to government continuity of operations as defined by the Department of 

Homeland Security.

8 Risk is a measure of the extent to which an entity is threatened by a potential circumstance or event, and a function of: 

(i) the adverse impacts that would arise if the circumstance or event occurs; and (ii) the likelihood of occurrence.

O

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providing essential information to senior leaders to facilitate decisions regarding the acceptance 

of risk to organizational operations and assets, individuals, other organizations, and the Nation 

arising from the operation and use of information systems.

The RMF has the following characteristics:

• Promotes the concept of near real-time risk management and ongoing information system 

authorization through the implementation of robust continuous monitoring processes;

• Encourages the use of automation to provide senior leaders the necessary information to 

make cost-effective, risk-based decisions with regard to the organizational information 

systems supporting their core missions and business functions;

• Integrates information security into the enterprise architecture and system development life 

cycle;

• Provides emphasis on the selection, implementation, assessment, and monitoring of security 

controls, and the authorization of information systems;

• Links risk management processes at the information system level to risk management

processes at the organization level through a risk executive (function); and

• Establishes responsibility and accountability for security controls deployed within 

organizational information systems and inherited by those systems (i.e., common controls).

The risk management process described in this publication changes the traditional focus of C&A 

as a static, procedural activity to a more dynamic approach that provides the capability to more 

effectively manage information system-related security risks in highly diverse environments of 

complex and sophisticated cyber threats, ever-increasing system vulnerabilities, and rapidly 

changing missions.

1.2 PURPOSE AND APPLICABILITY

The purpose of this publication is to provide guidelines for applying the Risk Management 

Framework to federal information systems to include conducting the activities of security 

categorization,9 security control selection and implementation, security control assessment, 

information system authorization,10 and security control monitoring. The guidelines have been 

developed:

• To ensure that managing information system-related security risks is consistent with the 

organization’s mission/business objectives and overall risk strategy established by the senior 

leadership through the risk executive (function);

• To ensure that information security requirements, including necessary security controls, are 

integrated into the organization’s enterprise architecture and system development life cycle 

processes;

9 FIPS 199 provides security categorization guidance for nonnational security systems. CNSS Instruction 1253 provides 

similar guidance for national security systems.

10 Security authorization is the official management decision given by a senior organizational official to authorize 

operation of an information system and to explicitly accept the risk to organizational operations and assets, individuals, 

other organizations, and the Nation based on the implementation of an agreed-upon set of security controls.

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• To support consistent, well-informed, and ongoing security authorization decisions (through 

continuous monitoring), transparency of security and risk management-related information, 

and reciprocity;11 and

• To achieve more secure information and information systems within the federal government 

through the implementation of appropriate risk mitigation strategies.

This publication satisfies the requirements of the Federal Information Security Management Act 

(FISMA) and meets or exceeds the information security requirements established for executive 

agencies12 by the Office of Management and Budget (OMB) in Circular A-130, Appendix III, 

Security of Federal Automated Information Resources. The guidelines in this publication are 

applicable to all federal information systems other than those systems designated as national 

security systems as defined in 44 U.S.C., Section 3542. The guidelines have been broadly 

developed from a technical perspective to complement similar guidelines for national security 

systems and may be used for such systems with the approval of appropriate federal officials 

exercising policy authority over such systems. State, local, and tribal governments, as well as 

private sector organizations are encouraged to consider using these guidelines, as appropriate.13

1.3 TARGET AUDIENCE

This publication serves individuals associated with the design, development, implementation, 

operation, maintenance, and disposition of federal information systems including:

• Individuals with mission/business ownership responsibilities or fiduciary responsibilities 

(e.g., heads of federal agencies, chief executive officers, chief financial officers);

• Individuals with information system development and integration responsibilities (e.g., 

program managers, information technology product developers, information system 

developers, information systems integrators, enterprise architects, information security 

architects);

• Individuals with information system and/or security management/oversight responsibilities 

(e.g., senior leaders, risk executives, authorizing officials, chief information officers, senior 

information security officers14);

11 Reciprocity is the mutual agreement among participating organizations to accept each other’s security assessments in 

order to reuse information system resources and/or to accept each other’s assessed security posture in order to share 

information. Reciprocity is best achieved by promoting the concept of transparency (i.e., making sufficient evidence 

regarding the security state of an information system available, so that an authorizing official from another organization 

can use that evidence to make credible, risk-based decisions regarding the operation and use of that system or the 

information it processes, stores, or transmits).

12 An executive agency is: (i) an executive department specified in 5 U.S.C., Section 101; (ii) a military department 

specified in 5 U.S.C., Section 102; (iii) an independent establishment as defined in 5 U.S.C., Section 104(1); and (iv) a 

wholly owned government corporation fully subject to the provisions of 31 U.S.C., Chapter 91. In this publication, the 

term executive agency is synonymous with the term federal agency.

13 In accordance with the provisions of FISMA and OMB policy, whenever the interconnection of federal information 

systems to information systems operated by state/local/tribal governments, contractors, or grantees involves the 

processing, storage, or transmission of federal information, the information security standards and guidelines described 

in this publication apply. Specific information security requirements and the terms and conditions of the system 

interconnections, are expressed in the Memorandums of Understanding and Interconnection Security Agreements 

established by participating organizations.

14 At the agency level, this position is known as the Senior Agency Information Security Officer. Organizations also

refer to this position as the Chief Information Security Officer.

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• Individuals with information system and security control assessment and monitoring 

responsibilities (e.g., system evaluators, assessors/assessment teams, independent verification 

and validation assessors, auditors, or information system owners); and

• Individuals with information security implementation and operational responsibilities (e.g., 

information system owners, common control providers, information owners/stewards, 

mission/business owners, information security architects, information system security 

engineers/officers).

1.4 ORGANIZATION OF THIS SPECIAL PUBLICATION

The remainder of this special publication is organized as follows:

• Chapter Two describes the fundamental concepts associated with managing information 

system-related security risks including: (i) an organization-wide view of risk management 

and the application of the Risk Management Framework; (ii) the integration of information 

security requirements into the system development life cycle; (iii) the establishment of 

information system boundaries; and (iv) the allocation of security controls to organizational 

information systems as system-specific, hybrid, or common controls.

• Chapter Three describes the tasks required to apply the Risk Management Framework to 

information systems including: (i) the categorization of information and information systems; 

(ii) the selection of security controls; (iii) the implementation of security controls; (iv) the 

assessment of security control effectiveness; (v) the authorization of the information system; 

and (vi) the ongoing monitoring of security controls and the security state of the information 

system.

• Supporting appendices provide additional information regarding the application of the Risk 

Management Framework to information systems including: (i) references; (ii) glossary; (iii) 

acronyms; (iv) roles and responsibilities; (v) summary of Risk Management Framework 

tasks; (vi) security authorization of information systems; (vii) monitoring the security state of 

information systems; (viii) operational scenarios; and (ix) security controls in external 

environments.

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CHAPTER TWO

THE FUNDAMENTALS

MANAGING INFORMATION SYSTEM-RELATED SECURITY RISKS

his chapter describes the basic concepts associated with managing information systemrelated security risks. These concepts include: (i) incorporating risk management principles 

and best practices into organization-wide strategic planning considerations, core missions 

and business processes, and supporting organizational information systems; (ii) integrating 

information security requirements into system development life cycle processes; (iii) establishing 

practical and meaningful boundaries for organizational information systems; and (iv) allocating 

security controls to organizational information systems as system-specific, hybrid, or common 

controls.

2.1 INTEGRATED ORGANIZATION-WIDE RISK MANAGEMENT

Managing information system-related security risks is a complex, multifaceted undertaking that 

requires the involvement of the entire organization—from senior leaders providing the strategic 

vision and top-level goals and objectives for the organization, to mid-level leaders planning and 

managing projects, to individuals on the front lines developing, implementing, and operating the 

systems supporting the organization’s core missions and business processes. Risk management 

can be viewed as a holistic activity that is fully integrated into every aspect of the organization. 

Figure 2-1 illustrates a three-tiered approach to risk management that addresses risk-related 

concerns at: (i) the organization level; (ii) the mission and business process level; and (iii) the 

information system level.15

FIGURE 2-1: TIERED RISK MANAGEMENT APPROACH

15 NIST Special Publication 800-39, Integrated Enterprise-Wide Risk Management: Organization, Mission, and 

Information System View (projected for publication in 2010), will provide guidance on the holistic approach to risk 

management.

T

TIER 1

ORGANIZATION

(Governance)

TIER 2

MISSION / BUSINESS PROCESS

(Information and Information Flows)

TIER 3

INFORMATION SYSTEM

(Environment of Operation)

- Multitier Organization-Wide Risk Management 

- Implemented by the Risk Executive (Function)

- Tightly coupled to Enterprise Architecture

and Information Security Architecture

- System Development Life Cycle Focus

- Disciplined and Structured Process

- Flexible and Agile Implementation

TACTICAL RISK

STRATEGIC RISK

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Tier 1 addresses risk from an organizational perspective with the development of a comprehensive 

governance structure and organization-wide risk management strategy that includes: (i) the 

techniques and methodologies the organization plans to employ to assess information systemrelated security risks and other types of risk of concern to the organization;16 (ii) the methods and 

procedures the organization plans to use to evaluate the significance of the risks identified during 

the risk assessment; (iii) the types and extent of risk mitigation measures the organization plans to 

employ to address identified risks; (iv) the level of risk the organization plans to accept (i.e., risk 

tolerance); (v) how the organization plans to monitor risk on an ongoing basis given the 

inevitable changes to organizational information systems and their environments of operation; 

and (vi) the degree and type of oversight the organization plans to use to ensure that the risk 

management strategy is being effectively carried out. As part of the overall governance structure 

established by the organization, the risk management strategy is propagated to organizational 

officials and contractors with programmatic, planning, developmental, acquisition, operational, 

and oversight responsibilities, including for example: (i) authorizing officials; (ii) chief 

information officers; (iii) senior information security officers; (iv) enterprise/information security 

architects; (v) information system owners/program managers; (vi) information owners/stewards; 

(vii) information system security officers; (viii) information system security engineers; (ix) 

information system developers and integrators; (x) system administrators; (xi) contracting 

officers; and (xii) users.

Tier 2 addresses risk from a mission and business process perspective and is guided by the risk 

decisions at Tier 1. Tier 2 activities are closely associated with enterprise architecture17 and include: 

(i) defining the core missions and business processes for the organization (including any 

derivative or related missions and business processes carried out by subordinate organizations); 

(ii) prioritizing missions and business processes with respect to the goals and objectives of the 

organization; (iii) defining the types of information that the organization needs to successfully 

execute the stated missions and business processes and the information flows both internal and 

external to the organization; (iv) developing an organization-wide information protection strategy 

and incorporating high-level information security requirements18 into the core missions and 

business processes; and (v) specifying the degree of autonomy for subordinate organizations (i.e., 

organizations within the parent organization) that the parent organization permits for assessing, 

evaluating, mitigating, accepting, and monitoring risk.

Because subordinate organizations responsible for carrying out derivative or related missions and 

business processes may have already invested in their own methods of assessing, evaluating, 

mitigating, accepting and monitoring risk, parent organizations may allow a greater degree of 

autonomy within parts of the organization or across the entire organization in order to minimize 

costs. When a diversity of risk assessment methods is allowed, organizations may choose to 

employ when feasible, some means of translation and/or synthesis of the risk-related information 

to ensure that the output of the different risk assessment activities can be correlated in a 

meaningful manner.

16 Types of risk include, for example: (i) program/acquisition risk (cost, schedule, performance); (ii) compliance and 

regulatory risk; (iii) financial risk; (iv) legal risk; (v) operational (mission/business) risk; (vi) political risk; (vii) project 

risk; (viii) reputational risk; (ix) safety risk; (x) strategic planning risk; and (xi) supply chain risk.

17 Federal Enterprise Architecture Reference Models and Segment and Solution Architectures are defined in the OMB 

Federal Enterprise Architecture (FEA) Program, FEA Consolidated Reference Model Document, Version 2.3, October 

2003 and OMB Federal Segment Architecture Methodology (FSAM), January 2009, respectively.

18 Information security requirements can be obtained from a variety of sources (e.g., legislation, policies, directives, 

regulations, standards, and organizational mission/business/operational requirements). Organization-level security 

requirements are documented in the information security program plan or equivalent document.

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Tier 3 addresses risk from an information system perspective and is guided by the risk decisions at 

Tiers 1 and 2. Risk decisions at Tiers 1 and 2 impact the ultimate selection and deployment of 

needed safeguards and countermeasures (i.e., security controls) at the information system level. 

Information security requirements are satisfied by the selection of appropriate management, 

operational, and technical security controls from NIST Special Publication 800-53.19 The security 

controls are subsequently allocated to the various components of the information system as 

system-specific, hybrid, or common controls in accordance with the information security 

architecture developed by the organization.20 Security controls are typically traceable to the 

security requirements established by the organization to ensure that the requirements are fully 

addressed during design, development, and implementation of the information system. Security 

controls can be provided by the organization or by an external provider. Relationships with 

external providers are established in a variety of ways, for example, through joint ventures, 

business partnerships, outsourcing arrangements (i.e., through contracts, interagency agreements, 

lines of business arrangements), licensing agreements, and/or supply chain arrangements.21

Risk management tasks begin early in the system development life cycle and are important in 

shaping the security capabilities of the information system. If these tasks are not adequately 

performed during the initiation, development, and acquisition phases of the system development 

life cycle, the tasks will, by necessity, be undertaken later in the life cycle and be more costly to 

implement. In either situation, all tasks are completed prior to placing the information system into 

operation or continuing its operation to ensure that: (i) information system-related security risks 

are being adequately addressed on an ongoing basis; and (ii) the authorizing official explicitly 

understands and accepts the risk to organizational operations and assets, individuals, other 

organizations, and the Nation based on the implementation of a defined set of security controls 

and the current security state of the information system.

The Risk Management Framework (RMF), illustrated in Figure 2-2, provides a disciplined and 

structured process that integrates information security and risk management activities into the 

system development life cycle. The RMF operates primarily at Tier 3 in the risk management 

hierarchy but can also have interactions at Tiers 1 and 2 (e.g., providing feedback from ongoing 

authorization decisions to the risk executive [function], dissemination of updated threat and risk 

information to authorizing officials and information system owners). The RMF steps include:

• Categorize the information system and the information processed, stored, and transmitted by 

that system based on an impact analysis.22

• Select an initial set of baseline security controls for the information system based on the 

security categorization; tailoring and supplementing the security control baseline as needed 

based on an organizational assessment of risk and local conditions.23

19 The RMF categorization step, including consideration of legislation, policies, directives, regulations, standards, and 

organizational mission/business/operational requirements, facilitates the identification of security requirements.

20 The allocation of security controls can take place at all three tiers in the risk management hierarchy. For example, 

security controls that are identified as common controls may be allocated at the organization, mission/business process, 

or information system level. See Section 2.4 for additional information on security control allocation.

21 Appendix I provides additional guidance regarding external service providers and the provision of security controls 

in external environments.

22 FIPS 199 provides security categorization guidance for nonnational security systems. CNSS Instruction 1253 

provides similar guidance for national security systems.

23 NIST Special Publication 800-53 provides security control selection guidance for nonnational security systems. 

CNSS Instruction 1253 provides similar guidance for national security systems.

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• Implement the security controls and describe how the controls are employed within the 

information system and its environment of operation.

• Assess the security controls using appropriate assessment procedures to determine the extent 

to which the controls are implemented correctly, operating as intended, and producing the 

desired outcome with respect to meeting the security requirements for the system.

• Authorize information system operation based on a determination of the risk to 

organizational operations and assets, individuals, other organizations, and the Nation 

resulting from the operation of the information system and the decision that this risk is 

acceptable. 

• Monitor the security controls in the information system on an ongoing basis including 

assessing control effectiveness, documenting changes to the system or its environment of 

operation, conducting security impact analyses of the associated changes, and reporting the 

security state of the system to designated organizational officials.

Chapter Three provides a detailed description of each of the specific tasks necessary to carry out 

the six steps in the RMF.

FIGURE 2-2: RISK MANAGEMENT FRAMEWORK

In summary, there is a significant degree of flexibility in how organizations employ the risk 

management processes described above. While it is convenient to portray the risk management 

approach in Figure 2-1 as hierarchical, the reality of project and organization dynamics can be 

much more complex. The organizational management style may be at one or more points on the 

continuum from top-down command to consensus among peers. For risk management to succeed 

Starting 

Point

RISK

MANAGEMENT

FRAMEWORK

PROCESS

OVERVIEW

Architecture Description

Architecture Reference Models

Segment and Solution Architectures

Mission and Business Processes

Information System Boundaries

Organizational Inputs

Laws, Directives, Policy Guidance

Strategic Goals and Objectives

Priorities and Resource Availability

Supply Chain Considerations

Repeat as necessary

Step 6

MONITOR

Security Controls

Step 2

SELECT

Security Controls

Step 3

IMPLEMENT

Security Controls Step 4

ASSESS

Security Controls

Step 5

AUTHORIZE

Information System

Step 1

CATEGORIZE

Information System

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at all levels of the organization, the organization must have a consistent and effective approach to 

risk management that is applied to all risk management processes and procedures. Organizational 

officials identify the resources necessary to complete the risk management tasks described in this 

publication and ensure that those resources are made available to appropriate personnel. Resource 

allocation includes both funding to carry out the risk management tasks and assigning qualified 

personnel needed to accomplish the tasks.24

2.2 SYSTEM DEVELOPMENT LIFE CYCLE

All federal information systems, including operational systems, systems under development, and 

systems undergoing modification or upgrade, are in some phase of a system development life 

cycle.25 Requirements definition is a critical part of any system development process and begins 

very early in the life cycle, typically in the initiation phase.26 Security requirements are a subset 

of the overall functional and nonfunctional (e.g., quality, assurance) requirements levied on an 

information system and are incorporated into the system development life cycle simultaneously 

with the functional and nonfunctional requirements. Without the early integration of security 

requirements, significant expense may be incurred by the organization later in the life cycle to 

address security considerations that could have been included in the initial design. When security 

requirements are considered as an integral subset of other information system requirements, the 

resulting system has fewer weaknesses and deficiencies, and therefore, fewer vulnerabilities that 

can be exploited in the future.

Early integration of information security requirements into the system development life cycle is 

the most cost-effective and efficient method for an organization to ensure that its protection 

strategy is implemented. It also ensures that information security processes are not isolated from 

the other routine management processes employed by the organization to develop, implement, 

operate, and maintain information systems supporting ongoing missions and business functions.

In addition to incorporating information security requirements into the system development life 

cycle, security requirements are also integrated into the program, planning, and budgeting 

activities within the organization to ensure that resources are available when needed and 

program/project milestones are completed. The enterprise architecture provides a central record 

of this integration within an organization.

Ensuring that information security requirements are integrated into the organization’s system 

development life cycle processes regardless of the type of life cycle processes employed, helps 

facilitate development and implementation of more resilient information systems to reduce risk to 

organizational operations and assets, individuals, other organizations, and the Nation. This can be 

accomplished using the well-established concept of integrated project teams.

27 A responsible 

organizational official (e.g., agency head, mission or business owner, integrated project team 

leader, program manager, information system owner, authorizing official) ensures that security 

professionals are an integral part of any information system development activities from the 

initial definition of information security requirements at Tier 1 and Tier 2 to the selection of 

24 Resource requirements include funding for training organizational personnel to ensure that they can effectively carry 

out their assigned responsibilities.

25 There are typically five phases in a generic system development life cycle including: (i) initiation; (ii) development/ 

acquisition; (iii) implementation; (iv) operation/maintenance; and (v) disposal.

26 Organizations may employ a variety of system development life cycle processes including, for example, waterfall, 

spiral, or agile development.

27 Integrated project teams are multidisciplinary entities consisting of a number of individuals with a range of skills and 

roles to help facilitate the development of information systems that meet the requirements of the organization.

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security controls at Tier 3. Such consideration is used to foster close cooperation among personnel 

responsible for the design, development, implementation, operation, maintenance, and disposition 

of information systems and the information security professionals advising the senior leadership 

on appropriate security controls needed to adequately mitigate risk and protect critical missions 

and business functions.

Finally, organizations maximize the use of security-relevant information (e.g., assessment results, 

information system documentation, and other artifacts) generated during the system development 

life cycle to satisfy requirements for similar information needed for information security-related 

purposes. Similar security-relevant information concerning common controls, including security 

controls provided by external providers, is factored into the organization’s risk management 

process. The judicious reuse of security-relevant information by organizations is an effective 

method to help eliminate duplication of effort, reduce documentation, promote reciprocity, and 

avoid unnecessary costs that may result when security activities are conducted independently of 

system development life cycle processes. In addition, reuse promotes greater consistency of 

information used in the design, development, implementation, operation, maintenance, and 

disposition of an information system including security-related considerations.

2.3 INFORMATION SYSTEM BOUNDARIES

One of the most challenging problems for information system owners, authorizing officials, chief 

information officers, senior information security officers, and information security architects is 

identifying appropriate boundaries for organizational information systems.28 Well-defined 

boundaries establish the scope of protection for organizational information systems (i.e., what the 

organization agrees to protect under its direct management control or within the scope of its 

responsibilities) and include the people, processes, and information technologies that are part of 

the systems supporting the organization’s missions and business processes. Information system 

boundaries are established in coordination with the security categorization process and before the 

development of security plans. Information system boundaries that are too expansive (i.e., too 

many system components and/or unnecessary architectural complexity) make the risk 

management process extremely unwieldy and complex. Boundaries that are too limited increase 

the number of information systems that must be separately managed and as a consequence, 

unnecessarily inflate the total information security costs for the organization. The following 

sections provide general guidelines to assist organizations in establishing appropriate system 

boundaries to achieve cost-effective solutions for managing information security-related risks 

from the operation and use of information systems.

2.3.1 Establishing Information System Boundaries

The set of information resources29 allocated to an information system defines the boundary for 

that system. Organizations have significant flexibility in determining what constitutes an 

information system and its associated boundary. If a set of information resources is identified as 

an information system, the resources are generally under the same direct management control.30 

Direct management control does not necessarily imply that there is no intervening management. 

28 With regard to the risk management process and information security, the term information system boundary is 

synonymous with authorization boundary.

29 Information resources consist of information and related resources including personnel, equipment, funds, and 

information technology.

30 For information systems, direct management control involves budgetary, programmatic, or operational authority and 

associated responsibility and accountability.

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It is also possible for multiple information systems to be considered as independent subsystems31

of a more complex information system. This situation may arise in many organizations when 

smaller information systems are coalesced for purposes of risk management into a larger, more 

comprehensive system. On a larger scale, an organization may develop a system of systems

involving multiple independent information systems (possibly distributed across a widespread 

geographic area) supporting a set of common missions and/or business functions.32

In addition to consideration of direct management control, it may also be helpful for 

organizations to determine if the information resources being identified as an information system:

• Support the same mission/business objectives or functions and essentially the same operating 

characteristics and information security requirements; and

• Reside in the same general operating environment (or in the case of a distributed information 

system, reside in various locations with similar operating environments).33

Since commonality can change over time, this determination is revisited periodically as part of a 

continuous monitoring process carried out by the organization (see Section 3.6). While the above 

considerations may be useful to organizations in determining information system boundaries for 

purposes of risk management, they are not viewed as limiting the organization’s flexibility in 

establishing commonsense boundaries that promote effective information security within the 

available resources of the organization. Information system owners consult with authorizing 

officials, chief information officers, senior information security officers, information security 

architects, and the risk executive (function)34 when establishing or changing system boundaries. 

The process of establishing information system boundaries and the associated risk management 

implications is an organization-wide activity that includes careful negotiation among all key 

participants—taking into account mission and business requirements, technical considerations 

with respect to information security, and programmatic costs to the organization.

Software applications (e.g., database applications, Web applications) hosted by an information 

system are included in the risk management process since application security is critical to the 

overall security of the system.35 Software applications depend on the resources provided by the 

hosting information system and as such, can take advantage of (i.e., leverage) the security 

controls provided by the system to help provide a foundational level of protection for the hosted 

applications, when this type of inheritance is applicable. Additional application-level security 

controls are provided by the respective software applications, as needed. Organizations ensure 

that all security controls, including application-level controls employed in separate software 

applications, are managed and tracked on an ongoing basis. Application owners coordinate with 

information system owners to ensure that information security and risk management activities are 

carried out as seamlessly as possible among applications and hosting systems. This coordination 

includes, for example, consideration for: (i) the selection, implementation, assessment, and 

monitoring of security controls for hosted applications; (ii) the effects of changes to hosted 

applications on the overall security state of the information system and the missions and business 

31 A subsystem is a major subdivision of an information system consisting of information, information technology, and 

personnel that perform one or more specific functions.

32 The National Airspace System (NAS) operated by the Federal Aviation Administration (FAA) is an example of a 

system of systems.

33 Similarity of operating environments includes, for example, consideration of threat, policy, and management.

34 The roles and responsibilities of the risk executive (function) are described in Appendix D.

35 Software applications and information systems hosting the applications may be owned by different organizations.

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processes supported by that system; and (iii) the effects of changes to the information system on 

hosted applications. Employing strong configuration management and control processes within 

software applications and the hosting information system, and reusing security control assessment 

results helps to provide the necessary protection for applications.

Security controls provided by the hosted software application are documented in the security plan 

for the hosting information system and assessed for effectiveness during the risk management 

process (i.e., during the initial authorization of the information system and subsequently, during 

the continuous monitoring process). Application-level security controls are also assessed for 

effectiveness if the applications are added after the hosting information system is authorized to 

operate. Information system owners take appropriate measures to ensure that hosted applications 

do not affect the security state of the hosting system and obtain the necessary information from 

application owners to conduct security impact analyses, when needed.

2.3.2 Boundaries for Complex Information Systems

The application of security controls within a complex information system can present significant 

challenges to an organization. From a centralized development, implementation, and operations 

perspective, the information system owner, in collaboration with the authorizing official, senior 

information security officer, information security architect, and information system security 

engineer, examines the purpose of the information system and considers the feasibility of 

decomposing the complex system into more manageable subsystems. From a distributed 

development, implementation, and operations perspective, the organization recognizes that 

multiple entities, possibly operating under different policies, may be contributing to the 

development, implementation, and/or operations of the subsystems that compose the complex 

information system. In such a scenario, the organization is responsible for ensuring that these 

separate subsystems can work together in both a secure and functional manner. Treating an 

information system as multiple subsystems, each with its own subsystem boundary, facilitates a 

more targeted application of security controls to achieve adequate security and a more costeffective risk management process. Knowledge of the security properties of individual 

subsystems does not necessarily provide the complete knowledge of the security properties of the 

complex information system. The organization applies best practices in systems and security 

engineering and documents the decomposition of the information system in the security plan.

Information security architecture plays a key part in the security control selection and allocation 

process for a complex information system. This includes monitoring and controlling 

communications at key internal boundaries among subsystems and providing system-wide 

common controls (see Section 2.4) that meet or exceed the requirements of the constituent 

subsystems inheriting those system-wide common controls. One approach to security control 

selection and allocation is to categorize each identified subsystem (including dynamic subsystems 

as described in Section 2.3.3). Separately categorizing each subsystem does not change the 

overall categorization of the information system. Rather, it allows the subsystems to receive a 

separate and more targeted allocation of security controls from NIST Special Publication 800-53 

instead of deploying higher-impact controls across every subsystem. Another approach is to 

bundle smaller subsystems into larger subsystems within the overall complex information system, 

categorize each of the aggregated subsystems, and allocate security controls to the subsystems, as 

needed. While subsystems within complex information systems may exist as complete systems, 

the subsystems are, in most cases, not treated as independent entities because they are typically 

interdependent and interconnected.

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When the results of security categorizations for the identified subsystems are different, the 

organization carefully examines the interfaces, information flows, and security-relevant 

dependencies36 among subsystems and selects security controls for the interconnection of the 

subsystems to eliminate or reduce potential vulnerabilities in this area. This helps to ensure that 

the information system is adequately protected.37 Security controls for the interconnection of 

subsystems are also employed when the subsystems implement different security policies or are 

administered by different authorities. The extent to which the security controls are implemented 

correctly, operating as intended, and producing the desired outcome with respect to meeting the 

security requirements for the complex information system, can be determined by combining 

security control assessments at the subsystem level and adding system-level considerations 

addressing interface issues among subsystems. This approach facilitates a more targeted and costeffective risk management process by scaling the level of effort of the assessment in accordance 

with the subsystem security categorization and allowing for reuse of assessment results at the 

information system level. Figure 2-3 illustrates the concept of decomposition for a complex 

information system.

FIGURE 2-3: DECOMPOSITION OF COMPLEX INFORMATION SYSTEM

In the above example, an information system contains a system guard that monitors the flow of 

information between two local area networks. The information system can be partitioned into 

multiple subsystems: (i) local area network one; (ii) local area network two; (iii) the system guard 

separating the two networks; and (iv) several dynamic subsystems that become part of the system 

at various points in time (see Section 2.3.3). Each subsystem within the information system may 

be categorized individually. The security categorization of the information system as a whole is 

not changed by taking into consideration all of the individual subsystem categorizations. When all 

36 Subsystem interfaces include ports and protocols. Information flows address information transmitted between 

subsystems. Security-relevant dependencies refer to security functions/services (e.g., encryption, auditing), performed 

by one subsystem that are required by one or more of the other subsystems.

37 The types of interfaces and couplings among subsystems may introduce inadvertent weaknesses and vulnerabilities 

in a complex information system. For example, if a large organizational intranet is decomposed by enterprise services 

into smaller subsystems (e.g., severable subsystems such as local area network segments) and subsequently categorized 

individually, the specific protections at the subsystem level may allow a vector of attack against the intranet by 

erroneously selecting and implementing security controls that are not sufficiently strong with respect to the rest of the 

system. To avoid this situation, organizations carefully examine the interfaces among subsystems and take appropriate 

actions to eliminate potential vulnerabilities in this area, thus helping to ensure that the information system is 

adequately protected.

Information System Boundary

SUBSYSTEM

LAN TWO

Subsystem Boundary

SUBSYSTEM 

GUARD

Subsystem Boundary

SUBSYSTEM

LAN ONE

Subsystem Boundary

DYNAMIC SUBSYSTEM

Subsystem Boundary

DYNAMIC SUBSYSTEM

Subsystem Boundary

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subsystems within the complex information system have completed an initial security control 

assessment, the organization takes additional measures to ensure that: (i) security controls not 

included in the subsystem assessments are assessed for effectiveness; and (ii) the subsystems 

work together in a manner that meets the security requirements of the information system.38

2.3.3 Changing Technologies and the Effect on Information System Boundaries

Changes to current information technologies and computing paradigms add complications to the 

traditional tasks of establishing information system boundaries and protecting the missions and 

business processes supported by organizational information systems. In particular, net-centric 

architectures39 (e.g., service-oriented architectures [SOAs], cloud computing) introduce two 

important concepts: (i) dynamic subsystems; and (ii) external subsystems. While the concepts of 

dynamic subsystems and external subsystems (described in the following sections) are not new, 

the pervasiveness and frequency of their invocation in net-centric architectures can present 

organizations with significant new challenges.

Dynamic Subsystems

For many information systems, the determination of subsystems is established at system initiation 

and maintained throughout the life cycle of the system. However, there are some instances, most 

notably in net-centric architectures, where the subsystems that compose the system may not be 

present at all stages of the life cycle. Some subsystems may not become part of an information 

system until sometime after system initiation, while other subsystems may leave the system 

sometime prior to system termination. Generally, this will not impact the external boundary of the 

information system if the dynamic subsystems are in the system design and the appropriate 

security controls are reflected in the security plan. But it does impact the subsystems that exist 

within the boundary at any given point in time.

Dynamic subsystems that become part of an organizational information system at various points 

in time may or may not be under the direct control of the organization. These subsystems may be 

provided by external providers (e.g., through contracts, interagency agreements, lines of business 

arrangements, licensing agreements, and/or supply chain arrangements). Regardless of whether 

the subsystem is or is not controlled by the organization, the expectations of its capabilities have 

to be considered. The dynamic inclusion or exclusion of the subsystems may or may not require

reassessment of the information system as a whole. This is determined based on constraints and 

assumptions (e.g., functions the subsystems perform, connections to other subsystems and other 

information systems) imposed upon the subsystems at system design and incorporated in the 

security plan. So long as the subsystems conform to the identified constraints and assumptions, 

they can be dynamically added or removed from the information system without requiring 

reassessments of the entire system.

38 The organization can: (i) issue a single authorization for the entire complex information system (to include bundling 

assessment results from individual subsystem assessments and any additional assessment results at the system level); or 

(ii) implement a strategy for managing the risk associated with connecting separately authorized information systems 

when viewed as a system of systems.

39 A net-centric architecture is a complex system of systems comprised of subsystems and services that are part of a 

continuously evolving, complex community of people, devices, information, and services interconnected by a network 

that enhances information sharing and collaboration. A service-oriented architecture (SOA) is an example of a netcentric architecture.

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As noted above, the assumptions and constraints on the dynamic subsystems are reflected in the 

information system design and the security plan. The determination as to whether the subsystems 

conform to the assumptions and constraints is addressed during the continuous monitoring phase 

of the risk management process. Depending upon the nature of the subsystems (including the 

functions, connections, and relative trust relationships established with the subsystem providers), 

the determination of conformance may be performed in a manual or automated manner, and may 

occur prior to, or during the subsystem connecting/disconnecting to the information system.

External Subsystems

Another characteristic often apparent in net-centric architectures is that some of the subsystems 

(or components of subsystems)40 are outside of the direct control of the organization that owns the 

information system and authorizes its operation. The nature of such external subsystems can vary 

from organizations employing external cloud computing services to process, store, and transmit 

information to organizations allowing platforms under their control to host applications/services 

developed by some external entity. 

As noted in Appendix I (Security Controls in External Environments), FISMA and OMB policy 

require external providers handling federal information or operating information systems on 

behalf of the federal government to meet the same security requirements as federal agencies. 

These security requirements also apply to external subsystems storing, processing, or transmitting 

federal information and any services provided by or associated with the subsystem. Appendix I 

further notes that the assurance or confidence that the risk from using external services is at an 

acceptable level depends on the trust that the organization places in the external service provider. 

In some cases, the level of trust is based on the amount of direct control the organization is able to 

exert on the external service provider with regard to employment of security controls necessary 

for the protection of the service and the evidence brought forth as to the effectiveness of those 

controls. In other instances, trust may be based on other factors, such as the experience the 

organization has with the external service provider, and the confidence (trust) the organization 

has in the provider taking the correct actions. There are a variety of factors that can complicate 

the level of trust issue in the case of net-centric architectures to include:

• The delineation between what is owned by the external entity and the organization may be 

somewhat blurred (e.g., organization-owned platform executing external entity-developed 

service/application software or firmware);

• The degree of control the organization has over the external entity providing/supporting the 

subsystems/services may be very limited;

• The nature and content of the subsystems may be subject to rapid change; and

• The subsystems/services may be of such critical nature that they need to be incorporated into 

organizational information systems very rapidly. 

The consequence of the factors above is that some of the more traditional means of verifying the 

correct functioning of a subsystem and the effectiveness of security controls (e.g., clearly defined 

requirements, design analysis, testing and evaluation before deployment) may not be feasible for 

a net-centric subsystem/service. As a result, organizations may be left to depend upon the nature 

of the trust relationships with the suppliers of the net-centric subsystems/services as the basis for 

determining whether or not to allow/include the subsystems/services (e.g., use of GSA list of 

approved providers). Alternatively, organizations may allow such subsystems/services to be used 

40 In this context, the term subsystem includes the services provided by or associated with that subsystem.

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only in those instances where they have constrained the nature of information or process flow 

such that the organization believes that any potential adverse impact is manageable. Ultimately, 

when the level of trust in the external provider of subsystems/services is below expectations, the 

organization: (i) employs compensating controls; (ii) accepts a greater degree of risk; or (iii) does 

not obtain the service (i.e., performs its core missions and business operations with reduced levels 

of functionality or possibly no functionality at all).

2.4 SECURITY CONTROL ALLOCATION

There are three types of security controls for information systems that can be employed by an 

organization: (i) system-specific controls (i.e., controls that provide a security capability for a 

particular information system only); (ii) common controls (i.e., controls that provide a security 

capability for multiple information systems); or (iii) hybrid controls (i.e., controls that have both 

system-specific and common characteristics).41 The organization allocates security controls to an 

information system consistent with the organization’s enterprise architecture and information 

security architecture.42 This activity is carried out as an organization-wide activity involving 

authorizing officials, information system owners, chief information security officer, senior 

information security officer, enterprise architect, information security architect, information 

system security officers, common control providers, and risk executive (function).

As part of the information security architecture, organizations are encouraged to identify and 

implement security controls that can support multiple information systems efficiently and 

effectively as a common capability (i.e., common controls). When these controls are used to 

support a specific information system, they are referenced by that specific system as inherited 

controls. Common controls promote more cost-effective and consistent information security 

across the organization and can also simplify risk management activities. By allocating security 

controls to an information system as system-specific controls, hybrid controls, or common 

controls, the organization assigns responsibility and accountability to specific organizational 

entities for the overall development, implementation, assessment, authorization, and monitoring 

of those controls.

The organization has significant flexibility in deciding which families of security controls or 

specific controls from selected families in NIST Special Publication 800-53 are appropriate for 

the different types of allocations. Since the security control allocation process involves the 

assignment and provision of security capabilities derived from security controls, the organization 

ensures that there is effective communication among all entities either receiving or providing 

such capabilities. This communication includes, for example, ensuring that common control 

authorization results and continuous monitoring information are readily available to those 

organizational entities inheriting common controls, and that any changes to common controls are 

effectively communicated to those affected by such changes.43

41 NIST Special Publication 800-53 provides additional guidance on security controls for information systems.

42 Allocation is a term used to describe the process an organization employs: (i) to determine whether security controls 

are defined as system-specific, hybrid, or common; and (ii) to assign security controls to specific information system 

components responsible for providing a particular security capability (e.g., router, server, remote sensor). 

43 Communication regarding the security status of common (inherited) controls is essential irrespective of whether the 

common control provider is internal or external to the organization. Appendix I provides guidance for organizations 

relying on security controls in external environments including the types of contractual agreements and arrangements 

that are necessary to ensure appropriate security-relevant information is conveyed to the organization from external 

providers.

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Figure 2-4 illustrates security control allocation within an organization and using the RMF to 

produce information for senior leaders (including authorizing officials) on the ongoing security 

state of organizational information systems and the missions and business processes supported by 

those systems.

FIGURE 2-4: SECURITY CONTROL ALLOCATION

INFORMATION 

SYSTEM

System-specific 

Controls

Core Missions / Business Processes

Security Requirements

Policy Guidance

RISK EXECUTIVE FUNCTION

Organization-Wide Risk Governance and Oversight

Security 

Assessment 

Report

Security

Plan

Plan of Action 

and Milestones

Security 

Assessment 

Report

Security

Plan

Plan of Action 

and Milestones

INFORMATION 

SYSTEM

System-specific 

Controls

Authorization Decision

Authorization Decision

Authorization Decision

COMMON CONTROLS

Security Controls Inherited by Organizational Information Systems

Security 

Assessment 

Report

Plan of Action and 

Milestones

Security

Plan

Hybrid Controls

Hybrid Controls

RISK 

MANAGEMENT 

FRAMEWORK

(RMF)

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CHAPTER THREE

THE PROCESS

EXECUTING THE RISK MANAGEMENT FRAMEWORK TASKS

his chapter describes the process of applying the Risk Management Framework (RMF) to 

federal information systems.44 The process includes a set of well-defined risk-related tasks 

that are to be carried out by selected individuals or groups within well-defined 

organizational roles (e.g., risk executive [function], authorizing official, authorizing official 

designated representative, chief information officer, senior information security officer, enterprise 

architect, information security architect, information owner/steward, information system owner, 

common control provider, information system security officer, and security control assessor).45

Many risk management roles defined in this publication have counterpart roles defined in the 

routine system development life cycle processes carried out by organizations. Whenever possible 

and consistent with core missions/business processes, organizations align risk management roles 

with similar (or complementary) roles defined for the system development life cycle. RMF tasks 

are executed concurrently with or as part of system development life cycle processes, taking into 

account appropriate dependencies. This helps to ensure that organizations are effectively 

integrating the process of managing information system-related security risks with system 

development life cycle processes.

Each RMF task description includes the individual or group with the primary responsibility for 

carrying out the task, the supporting roles that may be called upon to assist in completing the task, 

the system development life cycle phase most closely associated with the task, supplemental 

guidance to help explain how the task is executed, and appropriate references for publications or 

Web sites with information related to the task.46 To summarize the key risk management-related 

activities to be carried out by the organization, a milestone checkpoint is provided for each step in 

the RMF. The milestone checkpoints contain a series of questions for the organization to help 

ensure that important activities described in a particular step in the RMF have been completed 

prior to proceeding to the next step.

The process of implementing the RMF tasks (i.e., the order and manner in which the tasks occur 

and are executed, the names of primary/supporting roles, the names and format of artifacts) may 

vary from organization to organization. The RMF tasks can be applied at appropriate phases in 

the system development life cycle. While the tasks appear in sequential order, there can be many 

points in the risk management process that require divergence from the sequential order including 

the need for iterative cycles between tasks and revisiting tasks. For example, the results from 

security control assessments can trigger remediation actions on the part of an information system 

owner, which can in turn require the reassessment of selected controls. Monitoring the security 

44 The process for managing risk described in this publication can be tailored to meet the needs of many communities 

of interest within the federal government including, for example, the Civil, Defense, and Intelligence Communities. 

Tailoring provides flexibility in applying the risk management concepts associated with the RMF in a manner that is 

most suitable for the organizations and the information systems involved.

45 Appendix D describes the roles and responsibilities of key participants involved in an organization’s risk 

management process.

46 A reference is included in the RMF task list if: (i) the reference is generally applicable to both national security 

systems and nonnational security systems; (ii) the reference for nonnational security systems has an equivalent or 

supporting reference for national security systems; or (iii) the reference relates to specific national security community 

guidance regarding the implementation of certain NIST standards or guidelines.

T

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controls in an information system can also generate a potential cycle of tracking changes to the 

system and its environment of operation, conducting security impact analyses, taking remediation 

actions, reassessing security controls, and reporting the security status of the system. There may 

also be other opportunities to diverge from the sequential nature of the tasks when it is more 

efficient or cost-effective to do so. For example, while the security control assessment tasks are 

listed after the security control implementation tasks, some organizations may choose to begin the 

assessment of certain controls as soon as they are implemented but prior to the complete 

implementation of all controls described in the security plan. This may result in the organization 

assessing the physical and environmental protection controls within a facility prior to assessing 

the security controls employed in the hardware and software components of the information 

system (which may be implemented at a later time). Regardless of the task ordering, the last step 

before an information system is placed into operation is the explicit acceptance of risk by the 

authorizing official.

RMF steps and associated tasks can be applied to both new development and legacy information 

systems. For legacy systems, organizations can use RMF Steps 1 through 3 to confirm that the 

security categorization has been completed and is appropriate and that the requisite security 

controls have been selected and allocated. Applying the first three steps in the RMF to legacy 

systems can be viewed as a gap analysis to determine if the necessary and sufficient security 

controls (i.e., system-specific, hybrid, and common controls) have been appropriately selected 

and allocated. Security control weaknesses and deficiencies, if discovered, can be subsequently 

addressed in RMF Steps 3 through 6 similar to new development systems. If no weaknesses or 

deficiencies are discovered in the security controls during the gap analysis and there is a current 

security authorization in effect, the organization can move directly to the last step in the RMF, 

continuous monitoring. If a current security authorization is not in place, the organization 

continues with RMF Steps 4 through 6.

The security categorization process influences the level of effort expended when implementing 

the RMF tasks. Information systems supporting the most critical and/or sensitive operations and 

assets within the organization as indicated by the security categorization, demand the greatest 

level of attention and effort to ensure that appropriate information security and risk mitigation are 

achieved. Most RMF tasks can be carried out by external providers with appropriate contractual 

agreements or other arrangements in place (see Appendix I). A summary table of the RMF tasks 

is provided in Appendix E.

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APPLICATION OF THE RISK MANAGEMENT FRAMEWORK

The Risk Management Framework and associated RMF tasks apply to both information system 

owners and common control providers. In addition to supporting the authorization of information 

systems, the RMF tasks support the selection, development, implementation, assessment, 

authorization, and ongoing monitoring of common controls inherited by organizational information 

systems. Execution of the RMF tasks by common control providers, both internal and external to the 

organization, helps to ensure that the security capabilities provided by the common controls can be 

inherited by information system owners with a degree of assurance appropriate for their information 

protection needs. This approach recognizes the importance of security control effectiveness within 

information systems and the infrastructure supporting those systems.

Since the tasks in the RMF are described in a sequential manner, organizations may choose to 

deviate from that sequential structure in order to be consistent with their established management 

and system development life cycle processes or to achieve more cost-effective and efficient 

solutions with regard to the execution of the tasks. Regardless of the task ordering, the last step 

before an information system is placed into operation is the explicit acceptance of risk by the 

authorizing official. Organizations may also execute certain RMF tasks in an iterative manner or in 

different phases of the system development life cycle. For example, security control assessments 

may be carried out during system development, system implementation, and system 

operation/maintenance (as part of continuous monitoring).

Organizations may also choose to expend a greater level of effort on certain RMF tasks and commit 

fewer resources to other tasks based on the level of maturity of selected processes and activities 

within the organization. Since the RMF is life cycle-based, there will be a need to revisit various tasks 

over time depending on how the organization manages changes to the information systems and the 

environments in which those systems operate. Managing information security-related risks for an 

information system is viewed as part of a larger organization-wide risk management activity carried 

out by senior leaders. The RMF must simultaneously provide a disciplined and structured approach 

to mitigating risks from the operation and use of organizational information systems and the flexibility 

and agility to support the core missions and business operations of the organization in highly 

dynamic environments of operation.

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3.1 RMF STEP 1 – CATEGORIZE INFORMATION SYSTEM

SECURITY CATEGORIZATION

TASK 1-1: Categorize the information system and document the results of the security categorization in the 

security plan.

Primary Responsibility: Information System Owner; Information Owner/Steward.

Supporting Roles: Risk Executive (Function); Authorizing Official or Designated Representative; Chief Information 

Officer; Senior Information Security Officer; Information System Security Officer.

System Development Life Cycle Phase: Initiation (concept/requirements definition).

Supplemental Guidance: The security categorization process is carried out by the information system owner and 

information owner/steward in cooperation and collaboration with appropriate organizational officials (i.e., senior 

leaders with mission/business function and/or risk management responsibilities). The security categorization process is 

conducted as an organization-wide activity taking into consideration the enterprise architecture and the information 

security architecture. This helps to ensure that individual information systems are categorized based on the mission and 

business objectives of the organization. The information system owner and information owner/steward consider results 

from the initial risk assessment as a part of the security categorization decision. The security categorization decision is 

consistent with the organization’s risk management strategy to identify potential impact to mission/business functions 

resulting from the loss of confidentiality, integrity, and/or availability. The risk management strategy provides guidance 

and relevant information to authorizing officials (e.g., risk assessment methodologies employed by the organization, 

evaluation of risks determined, risk mitigation approaches, organizational risk tolerance, approaches for monitoring risk 

over time, known existing aggregated risks from current information systems, and other sources of risk).

The results of the security categorization process influence the selection of appropriate security controls for the 

information system and also, where applicable, the minimum assurance requirements for that system. Security 

categorization determinations consider potential adverse impacts to organizational operations, organizational assets, 

individuals, other organizations, and the Nation. The organization may consider decomposing the information system 

into multiple subsystems to more efficiently and effectively allocate security controls to the system. One approach is to 

categorize each identified subsystem (including dynamic subsystems). Separately categorizing each subsystem does not 

change the overall categorization of the information system. Rather, it allows the constituent subsystems to receive a 

separate allocation of security controls from NIST Special Publication 800-53 instead of deploying higher-impact 

controls across every subsystem. Another approach is to bundle smaller subsystems into larger subsystems within the 

information system, categorize each of the aggregated subsystems, and allocate security controls to the subsystems, as 

appropriate. Security categorization information is documented in the system identification section of the security plan 

or included as an attachment to the plan.

References: FIPS Publication 199; NIST Special Publications 800-30, 800-39, 800-59, 800-60; CNSS Instruction 

1253.

INFORMATION SYSTEM DESCRIPTION

TASK 1-2: Describe the information system (including system boundary) and document the description in 

the security plan.

Primary Responsibility: Information System Owner.

Supporting Roles: Authorizing Official or Designated Representative; Senior Information Security Officer; 

Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Initiation (concept/requirements definition).

Supplemental Guidance: Descriptive information about the information system is documented in the system 

identification section of the security plan, included in attachments to the plan, or referenced in other standard sources 

for information generated as part of the system development life cycle. Duplication of information is avoided, 

whenever possible. The level of detail provided in the security plan is determined by the organization and is typically 

commensurate with the security categorization of the information system. Information may be added to the system 

description as it becomes available during the system development life cycle and execution of the RMF tasks. A system 

description may include, for example:

- Full descriptive name of the information system including associated acronym;

- Unique information system identifier (typically a number or code);

- Information system owner and authorizing official including contact information;

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- Parent or governing organization that manages, owns, and/or controls the information system;

- Location of the information system and environment in which the system operates;

- Version or release number of the information system;

- Purpose, functions, and capabilities of the information system and missions/business processes supported;

- How the information system is integrated into the enterprise architecture and information security architecture;

- Status of the information system with respect to acquisition and/or system development life cycle;

- Results of the security categorization process for the information and information system;

- Types of information processed, stored, and transmitted by the information system;

- Boundary of the information system for risk management and security authorization purposes;

- Applicable laws, directives, policies, regulations, or standards affecting the security of the information system;

- Architectural description of the information system including network topology;

- Hardware and firmware devices included within the information system;

- System and applications software resident on the information system;

- Hardware, software, and system interfaces (internal and external);

- Subsystems (static and dynamic) associated with the information system;

- Information flows and paths (including inputs and outputs) within the information system;

- Cross domain devices/requirements;

- Network connection rules for communicating with external information systems;

- Interconnected information systems and identifiers for those systems;

- Encryption techniques used for information processing, transmission, and storage;

- Cryptographic key management information (public key infrastructures, certificate authorities, etc.);

- Information system users (including organizational affiliations, access rights, privileges, citizenship, if applicable);

- Ownership/operation of information system (e.g., government-owned, government-operated; government-owned, 

contractor-operated; contractor-owned, contractor-operated; nonfederal [state and local governments, grantees]);

- Security authorization date and authorization termination date;

- Incident response points of contact; and

- Other information as required by the organization.

References: None.

INFORMATION SYSTEM REGISTRATION

TASK 1-3: Register the information system with appropriate organizational program/management offices.

Primary Responsibility: Information System Owner.

Supporting Roles: Information System Security Officer.

System Development Life Cycle Phase: Initiation (concept/requirements definition).

Supplemental Guidance: The registration process begins by identifying the information system (and subsystems, if 

appropriate) in the system inventory and establishes a relationship between the information system and the parent or 

governing organization that owns, manages, and/or controls the system. Information system registration, in accordance 

with organizational policy, uses information in the system identification section of the security plan to inform the 

parent or governing organization of: (i) the existence of the information system; (ii) the key characteristics of the 

system; and (iii) any security implications for the organization due to the ongoing operation of the system. Information 

system registration provides organizations with an effective management/tracking tool that is necessary for security 

status reporting in accordance with applicable laws, Executive Orders, directives, policies, standards, guidance, or 

regulations. Those subsystems that are more dynamic in nature (e.g., subsystems in net-centric architectures) may not 

be present throughout all phases of the system development life cycle. Such subsystems are registered either as a subset 

of a well-defined information system or a method of registration for dynamic subsystems is implemented that includes 

as much information as feasible. Some information about dynamic subsystems is known prior to the subsystem 

manifesting itself in the information system (e.g., assumptions and constraints specified in the security plan). However, 

more detailed information may not be known until the subsystem manifests itself.

References: None.

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Milestone Checkpoint #1

- Has the organization completed a security categorization of the information system (informed by the initial risk 

assessment) including the information to be processed, stored, and transmitted by the system?

- Are the results of the security categorization process for the information system consistent with the organization’s 

enterprise architecture and commitment to protecting organizational mission/business processes?

- Do the results of the security categorization process reflect the organization’s risk management strategy?

- Has the organization adequately described the characteristics of the information system?

- Has the organization registered the information system for purposes of management, accountability, coordination, and 

oversight?

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3.2 RMF STEP 2 – SELECT SECURITY CONTROLS

COMMON CONTROL IDENTIFICATION

TASK 2-1: Identify the security controls that are provided by the organization as common controls for 

organizational information systems and document the controls in a security plan (or equivalent document).

Primary Responsibility: Chief Information Officer or Senior Information Security Officer; Information Security 

Architect; Common Control Provider.

Supporting Roles: Risk Executive (Function); Authorizing Official or Designated Representative; Information System 

Owner; Information System Security Engineer.

System Development Life Cycle Phase: Initiation (concept/requirements definition).

Supplemental Guidance: Common controls are security controls that are inherited by one or more organizational 

information systems. Common controls are identified by the chief information officer and/or senior information 

security officer in collaboration with the information security architect and assigned to specific organizational entities 

(designated as common control providers) for development, implementation, assessment, and monitoring. Common 

control providers may also be information system owners when the common controls are resident within an information 

system. The organization consults information system owners when identifying common controls to ensure that the 

security capability provided by the inherited controls is sufficient to deliver adequate protection. When the common 

controls provided by the organization are not sufficient for information systems inheriting the controls, the system 

owners supplement the common controls with system-specific or hybrid controls to achieve the required protection for 

the system and/or accept greater risk. Information system owners inheriting common controls can either document the 

implementation of the controls in their respective security plans or reference the controls contained in the security plans 

of the common control providers. Organizations may choose to defer common control identification and security 

control selection until a later phase in the system development life cycle. When common controls are not resident 

within an information system (e.g., physical and environmental protection controls, personnel security controls), the 

organization selects one or more senior organizational officials or executives to serve as authorizing officials for those 

controls. These authorizing officials are responsible for accepting the risk to organizational operations and assets, 

individuals, other organizations, and the Nation resulting from the deployment of the security controls provided by 

common control providers and inherited by organizational information systems. Common control providers are 

responsible for: (i) documenting common controls in a security plan (or equivalent document prescribed by the 

organization); (ii) ensuring that common controls are developed, implemented, and assessed for effectiveness by 

qualified assessors with a level of independence required by the organization; (iii) documenting assessment findings in 

a security assessment report; (iv) producing a plan of action and milestones for all common controls deemed less than 

effective (i.e., having unacceptable weaknesses or deficiencies in the controls); (v) receiving authorization for the 

common controls from the designated authorizing official; and (vi) monitoring common control effectiveness on an 

ongoing basis.

Security plans, security assessment reports, and plans of action and milestones for common controls (or a summary of 

such information) are made available to information system owners (whose systems are inheriting the controls) after 

the information is reviewed and approved by the senior official or executive responsible and accountable for the 

controls. The organization ensures that common control providers keep this information current since the controls 

typically support multiple organizational information systems. Security plans, security assessment reports, and plans of 

action and milestones for common controls are used by authorizing officials within the organization to make risk-based 

decisions in the security authorization process for their information systems. The use of common controls is 

documented within the security plans for information systems inheriting those controls. Organizations ensure that 

common control providers have the capability to rapidly broadcast changes in the status of common controls that 

adversely affect the protections being provided by and expected of the common controls. Common control providers 

are able to quickly inform information system owners when problems arise in the inherited common controls (e.g., 

when an assessment or reassessment of a common control indicates the control is flawed in some manner, when a new 

threat or attack method arises that renders the common control less than effective in protecting against the new threat or 

attack method). Organizations are encouraged, when feasible, to employ automated management systems to maintain 

records of the specific common controls used in each organizational information system to enhance the ability of 

common control providers to rapidly communicate with information system owners. If common controls are provided 

to the organization (and its information systems) by entities external to the organization (e.g., shared and/or external 

service providers), arrangements are made with the external/shared service providers by the organization to obtain 

information on the effectiveness of the deployed controls. Information obtained from external organizations regarding 

the effectiveness of common controls is factored into authorization decisions.

References: FIPS Publications 199, 200; NIST Special Publications 800-30, 800-53; CNSS Instruction 1253.

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SECURITY CONTROL SELECTION

TASK 2-2: Select the security controls for the information system and document the controls in the security 

plan.

Primary Responsibility: Information Security Architect; Information System Owner.

Supporting Roles: Authorizing Official or Designated Representative; Information Owner/Steward; Information 

System Security Officer; Information System Security Engineer.

System Development Life Cycle Phase: Initiation (concept/requirements definition).

Supplemental Guidance: The security controls are selected based on the security categorization of the information 

system. After selecting the applicable security control baseline, organizations apply the tailoring process to align the 

controls more closely with the specific conditions within the organization (i.e., conditions related to organizational risk 

tolerance, missions/business functions, information systems, or environments of operation). The tailoring process 

includes: (i) identifying and designating common controls in initial security control baselines; (ii) applying scoping 

considerations to the remaining baseline security controls; (iii) selecting compensating security controls, if needed; (iv) 

assigning specific values to organization-defined security control parameters via explicit assignment and selection 

statements; (v) supplementing baselines with additional security controls and control enhancements, if needed; and (vi) 

providing additional specification information for control implementation, if needed. Organizations use risk 

assessments to inform and guide the tailoring process for organizational information systems and environments of 

operation. Threat data from risk assessments provide critical information on adversary capabilities, intent, and targeting 

that may affect organizational decisions regarding the selection of additional security controls, including the associated 

costs and benefits. Risk assessment results are also leveraged when identifying common controls to help determine if 

such controls available for inheritance meet the security requirements for the system and its environment of operation

(including analyses for potential single points of failure). The security plan contains an overview of the security

requirements for the information system in sufficient detail to determine that the security controls selected would meet 

those requirements. The security plan, in addition to the list of security controls to be implemented, describes the 

intended application of each control in the context of the information system with sufficient detail to enable a compliant 

implementation of the control. During the security control selection process organizations may begin planning for the 

continuous monitoring process by developing a monitoring strategy. The strategy can include, for example, monitoring 

criteria such as the volatility of specific security controls and the appropriate frequency of monitoring specific controls. 

Organizations may choose to address security control volatility and frequency of monitoring during control selection as 

inputs to the continuous monitoring process. The monitoring strategy can be included in the security plan to support the 

concept of near real-time risk management and ongoing authorization (see Task 2-3). Information system owners 

inheriting common controls can either document the implementation of the controls in their respective security plans or 

reference the controls contained in the security plans of the common control providers (see Task 2-1). Information 

system owners can refer to the security authorization packages prepared by common control providers when making 

determinations regarding the adequacy of common controls inherited by their respective systems.

For net-centric architectures where subsystems may be added or removed from an information system dynamically, the 

organization includes in the security plan for the system: (i) descriptions of the functions of the dynamic subsystems; 

(ii) the security controls employed in the subsystems; (iii) constraints/assumptions regarding the functions of the 

dynamic subsystems and the associated security controls in the subsystems; (iv) dependencies of other subsystems on 

the proper functioning of the security controls of the dynamic subsystems; (v) procedures for determining that the 

dynamic subsystems conform to the security plan, assumptions, and constraints; and (vi) the impact of the dynamic 

subsystems and associated security controls on existing security controls in the information system. While inclusion of 

a dynamic subsystem may impact the information system or some of the currently identified subsystems, it does not 

necessarily mean the subsystem will impact the security of the system or other subsystems. That is, not all subsystems 

are security relevant. Changes in the net-centric architectures that exceed the anticipated limits of the security plan may 

not be allowed or may require reassessment prior to being approved. When security controls are designated as common 

controls, the organization ensures that sufficient information is available to information system owners and authorizing 

officials to support the risk management process. When security services are provided by external providers (e.g., 

through contracts, interagency agreements, lines of business arrangements, licensing agreements, and/or supply chain 

arrangements), the organization: (i) defines the external services provided to the organization; (ii) describes how the 

external services are protected in accordance with the security requirements of the organization; and (iii) obtains the 

necessary assurances that the risk to organizational operations and assets, individuals, other organizations, and the 

Nation arising from the use of the external services is acceptable. The organization also considers that replicated 

subsystems within a complex information system may exhibit common vulnerabilities that can be exploited by a 

common threat source, thereby negating the redundancy that might be relied upon as a risk mitigation measure. The 

impact due to a security incident against one constituent subsystem might cascade and impact many subsystems at the 

same time.

References: FIPS Publications 199, 200; NIST Special Publications 800-30, 800-53; CNSS Instruction 1253.

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MONITORING STRATEGY

TASK 2-3: Develop a strategy for the continuous monitoring of security control effectiveness and any 

proposed or actual changes to the information system and its environment of operation.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Risk Executive (Function); Authorizing Official or Designated Representative; Chief Information 

Officer; Senior Information Security Officer; Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Initiation (concept/requirements definition).

Supplemental Guidance: A critical aspect of risk management is the ongoing monitoring of security controls employed 

within or inherited by the information system. An effective monitoring strategy is developed early in the system 

development life cycle (i.e., during system design or COTS procurement decision) and can be included in the security 

plan. The implementation of a robust continuous monitoring program allows an organization to understand the security 

state of the information system over time and maintain the initial security authorization in a highly dynamic 

environment of operation with changing threats, vulnerabilities, technologies, and missions/business functions. The 

ongoing monitoring of security controls using automated tools and supporting databases facilitates near real-time risk 

management for the information system. An effective monitoring program includes: (i) configuration management and 

control processes; (ii) security impact analyses on proposed or actual changes to the information system and its 

environment of operation; (iii) assessment of security controls employed within and inherited by the information 

system (including controls in dynamic subsystems); and (iv) security status reporting to appropriate organizational 

officials. The continuous monitoring strategy for the information system identifies the security controls to be 

monitored, the frequency of monitoring, and the control assessment approach. The strategy defines how changes to the 

information system will be monitored, how security impact analyses will be conducted, and the security status reporting 

requirements including recipients of the status reports.

The criteria for determining the frequency with which security controls are monitored post deployment is established 

by the information system owner or common control provider in collaboration with selected organizational officials 

including, for example, the authorizing official or designated representative, chief information officer, senior 

information security officer, and risk executive (function). The frequency criteria reflect the priorities and importance 

of the information system to organizational operations and assets, individuals, other organizations, and the Nation. 

Security controls that are volatile (i.e., most likely to change over time), critical to certain aspects of the organization’s 

protection strategy, or identified in current plans of action and milestones may require more frequent assessment. The 

use of automation facilitates a greater frequency and volume of security control assessments.

Determining the frequency for assessing security controls inherited by the information system (i.e., common controls) 

includes the organization’s determination of the trustworthiness of the common control provider. An organizational 

assessment of risk (either formal or informal) can also be used to guide the frequency of monitoring. The approach to 

security control assessments during continuous monitoring may include detection of the status of information system 

components and analysis of historical, operational data, as well as the reuse of assessment procedures and results that 

supported the initial authorization decision.

The authorizing official or designated representative approve the monitoring strategy including the set of security 

controls that are to be monitored on an ongoing basis as well as the frequency of the monitoring activities. The 

approval of the monitoring strategy can be obtained in conjunction with the security plan approval. The monitoring of 

security controls continues throughout the system development life cycle. For security controls employed in 

information systems with dynamic subsystems, the monitoring strategy accounts for subsystems that did not exist at the 

beginning of the system development life cycle. An effective monitoring strategy for dynamic subsystems achieves an 

appropriate balance with regard to risk by: (i) not placing unnecessary or unrealistic burdens on the organization by 

requiring reauthorization of the information system each time a new subsystem is added or removed; and (ii) not 

compromising the accepted security posture of the overall system. NIST Special Publication 800-137 provides 

additional guidance on continuous monitoring and continuous monitoring strategies.

References: NIST Special Publications 800-30, 800-39, 800-53, 800-53A, 800-137; CNSS Instruction 1253.

SECURITY PLAN APPROVAL

TASK 2-4: Review and approve the security plan.

Primary Responsibility: Authorizing Official or Designated Representative.

Supporting Roles: Risk Executive (Function); Chief Information Officer; Senior Information Security Officer.

System Development Life Cycle Phase: Development/Acquisition.

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Supplemental Guidance: The independent review of the security plan by the authorizing official or designated 

representative with support from the senior information security officer, chief information officer, and risk executive 

(function), helps determine if the plan is complete, consistent, and satisfies the stated security requirements for the 

information system. The security plan review also helps to determine, to the greatest extent possible with available 

planning or operational documents, if the security plan correctly and effectively identifies the potential risk to 

organizational operations and assets, individuals, other organizations, and the Nation, that would be incurred if the 

controls identified in the plan were implemented as intended. Based on the results of this independent review and 

analysis, the authorizing official or designated representative, chief information officer, senior information security 

officer, or risk executive (function) may recommend changes to the security plan. If the security plan is deemed 

unacceptable, the authorizing official or designated representative sends the plan back to the information system owner 

(or common control provider) for appropriate action. If the security plan is deemed acceptable, the authorizing official 

or designated representative approves the plan. The acceptance of the security plan represents an important milestone in

both the risk management process and the system development life cycle. The authorizing official or designated 

representative, by approving the security plan, agrees to the set of security controls (system-specific, hybrid, and/or 

common controls) proposed to meet the security requirements for the information system. This approval allows the risk 

management process to advance to the next step in the RMF (i.e., the implementation of the security controls). The 

approval of the security plan also establishes the level of effort required to successfully complete the remainder of the 

steps in the RMF and provides the basis of the security specification for the acquisition of the information system, 

subsystems, or components. 

References: NIST Special Publications 800-30, 800-53; CNSS Instruction 1253.

Milestone Checkpoint #2

- Has the organization allocated all security controls to the information system as system-specific, hybrid, or common 

controls?

- Has the organization used its risk assessment (either formal or informal) to inform and guide the security control selection 

process?

- Has the organization identified authorizing officials for the information system and all common controls inherited by the 

system?

- Has the organization tailored the baseline security controls to ensure that the controls, if implemented, adequately mitigate 

risks to organizational operations and assets, individuals, other organizations, and the Nation?

- Has the organization addressed minimum assurance requirements for the security controls employed within and inherited 

by the information system?

- Has the organization consulted information system owners when identifying common controls to ensure that the security 

capability provided by the inherited controls is sufficient to deliver adequate protection?

- Has the organization supplemented the common controls with system-specific or hybrid controls when the security 

control baselines of the common controls are less than those of the information system inheriting the controls?

- Has the organization documented the common controls inherited from external providers?

- Has the organization developed a continuous monitoring strategy for the information system (including monitoring of 

security control effectiveness for system-specific, hybrid, and common controls) that reflects the organizational risk 

management strategy and organizational commitment to protecting critical missions and business functions?

- Have appropriate organizational officials approved security plans containing system-specific, hybrid, and common controls?

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3.3 RMF STEP 3 – IMPLEMENT SECURITY CONTROLS

SECURITY CONTROL IMPLEMENTATION

TASK 3-1: Implement the security controls specified in the security plan.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Information Owner/Steward; Information System Security Officer; Information System Security 

Engineer.

System Development Life Cycle Phase: Development/Acquisition; Implementation.

Supplemental Guidance: Security control implementation is consistent with the organization’s enterprise architecture 

and information security architecture. The information security architecture serves as a resource to allocate security 

controls (including, for example, security mechanisms and services) to an information system and any organizationdefined subsystems. Early integration of information security requirements into the system development life cycle is 

the most cost-effective method for implementing the organizational risk management strategy at Tier 3. Security 

controls targeted for deployment within the information system (including subsystems) are allocated to specific system 

components responsible for providing a particular security capability. Not all security controls need to be allocated to 

every subsystem. Categorization of subsystems, information security architecture, and allocation of security controls 

work together to help achieve a suitable balance. Allocating some security controls as common controls or hybrid 

controls is part of this architectural process. Organizations use best practices when implementing the security controls 

within the information system including system and software engineering methodologies, security engineering 

principles, and secure coding techniques. Risk assessment may help inform decisions regarding the cost, benefit, and 

risk trade-offs in using one type of technology versus another for control implementation. In addition, organizations 

ensure that mandatory configuration settings are established and implemented on information technology products in 

accordance with federal and organizational policies (e.g., Federal Desktop Core Configuration). Information system 

security engineers with support from information system security officers employ a sound security engineering process 

that captures and refines information security requirements and ensures the integration of those requirements into 

information technology products and systems through purposeful security design or configuration. When available, 

organizations consider the use of information technology products that have been tested, evaluated, or validated by 

approved, independent, third-party assessment facilities. In addition, organizations satisfy, where applicable, minimum 

assurance requirements when implementing security controls. Assurance requirements are directed at the activities and 

actions that security control developers and implementers define and apply to increase the level of confidence that the 

controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting 

the security requirements for the information system. Assurance requirements address the quality of the design, 

development, and implementation of the security functions in the information system. For higher-impact systems (i.e., 

potential high-value targets) in situations where specific and credible threat information indicates the likelihood of 

advanced cyber attacks, additional assurance measures are considered. Organizations consider any implementationrelated issues associated with the integration and/or interfaces among common controls and system-specific controls.

For the identified common controls inherited by the information system, information system security engineers with 

support from information system security officers coordinate with the common control provider to determine the most 

appropriate way to apply the common controls to the organizational information systems. For certain management and 

operational controls, formal integration into information technology products, services, and systems may not be 

required. For certain types of operational and/or technical controls, implementation may require additional components, 

products, or services to enable the information system to utilize the previously selected common controls to the fullest 

extent. If selection of common controls previously had been deferred, identification of common controls inherited by 

the information system is revisited to determine if better determinations can be made at this point in the system 

development life cycle. Information system owners can refer to the authorization packages prepared by common 

control providers when making determinations regarding the adequacy of the implementations of common controls for 

their respective systems. For common controls that do not meet the protection needs of the information systems 

inheriting the controls or that have unacceptable weaknesses or deficiencies, the system owners identify compensating 

or supplementary controls to be implemented. Risk assessment may help determine how gaps in protection needs 

between systems and common controls affect the overall risk associated with the system, and how to prioritize the need 

for compensating or supplementary controls to mitigate specific risks. To the maximum extent and consistent with the 

flexibility allowed in applying the tasks in the RMF, organizations and their contractors conduct initial security control 

assessments (also referred to as developmental testing and evaluation) during information system development and 

implementation. Conducting security control assessments in parallel with the development and implementation phases 

of the system development life cycle facilitates the early identification of weaknesses and deficiencies and provides the 

most cost-effective method for initiating corrective actions. Issues found during these assessments can be referred to 

authorizing officials for early resolution, as appropriate. The results of the initial security control assessments can also 

be used during the security authorization process to avoid delays or costly repetition of assessments. Assessment results 

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that are subsequently reused in other phases of the system development life cycle meet the reuse requirements 

(including independence) established by the organization.

References: FIPS Publication 200; NIST Special Publications 800-30, 800-53, 800-53A; CNSS Instruction 1253; Web: 

SCAP.NIST.GOV.

SECURITY CONTROL DOCUMENTATION

TASK 3-2: Document the security control implementation, as appropriate, in the security plan, providing a 

functional description of the control implementation (including planned inputs, expected behavior, and 

expected outputs).

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Information Owner/Steward; Information System Security Officer; Information System Security 

Engineer.

System Development Life Cycle Phase: Development/Acquisition; Implementation.

Supplemental Guidance: Security control documentation describes how system-specific, hybrid, and common controls 

are implemented. The documentation formalizes plans and expectations regarding the overall functionality of the 

information system. The functional description of the security control implementation includes planned inputs, 

expected behavior, and expected outputs where appropriate, typically for those technical controls that are employed in 

the hardware, software, or firmware components of the information system. Documentation of security control 

implementation allows for traceability of decisions prior to and after deployment of the information system. The level 

of effort expended on documentation of the information system is commensurate with the purpose, scope, and impact 

of the system with respect to organizational missions, business functions, and operations. To the extent possible, 

organizations reference existing documentation (either by vendors or other organizations that have employed the same 

or similar information systems), use automated support tools, and maximize communications to increase the overall 

efficiency and cost effectiveness of security control implementation. The documentation also addresses platform 

dependencies and includes any additional information necessary to describe how the security capability required by the 

security control is achieved at the level of detail sufficient to support control assessment. Documentation for security 

control implementation follows best practices for hardware and software development as well as for system/security 

engineering disciplines and is consistent with established organizational policies and procedures for documenting 

system development life cycle activities. Whenever possible and practicable for technical security controls that are 

mechanism-based, organizations take maximum advantage of functional specifications provided by or obtainable from 

hardware and software vendors and/or systems integrators including security-relevant documentation that may assist 

the organization during the assessment and monitoring of the controls. Similarly, for management and operational 

controls, organizations obtain security control implementation information from appropriate organizational entities 

(e.g., facilities offices, human resource offices, physical security offices). Since the enterprise architecture and 

information security architecture established by the organization significantly influence the approach used to 

implement security controls, providing documentation of this process helps to ensure traceability with regard to 

meeting the organization’s information security requirements.

References: NIST Special Publication 800-53; CNSS Instruction 1253.

Milestone Checkpoint #3

- Has the organization allocated security controls as system-specific, hybrid, or common controls consistent with the 

enterprise architecture and information security architecture?

- Has the organization demonstrated the use of sound information system and security engineering methodologies in 

integrating information technology products into the information system and in implementing the security controls contained 

in the security plan?

- Has the organization documented how common controls inherited by organizational information systems have been 

implemented?

- Has the organization documented how system-specific and hybrid security controls have been implemented within the 

information system taking into account specific technologies and platform dependencies?

- Has the organization taken into account the minimum assurance requirements when implementing security controls?

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3.4 RMF STEP 4 – ASSESS SECURITY CONTROLS

ASSESSMENT PREPARATION

TASK 4-1: Develop, review, and approve a plan to assess the security controls.

Primary Responsibility: Security Control Assessor.

Supporting Roles: Authorizing Official or Designated Representative; Chief Information Officer; Senior Information 

Security Officer; Information System Owner or Common Control Provider; Information Owner/Steward; Information 

System Security Officer.

System Development Life Cycle Phase: Development/Acquisition; Implementation.

Supplemental Guidance: The security assessment plan provides the objectives for the security control assessment, a 

detailed roadmap of how to conduct such an assessment, and assessment procedures. The assessment plan reflects the 

type of assessment the organization is conducting (e.g., developmental testing and evaluation, independent verification 

and validation, assessments supporting security authorizations or reauthorizations, audits, continuous monitoring, 

assessments subsequent to remediation actions). Conducting security control assessments in parallel with the 

development/acquisition and implementation phases of the life cycle permits the identification of weaknesses and 

deficiencies early and provides the most cost-effective method for initiating corrective actions. Issues found during 

these assessments can be referred to authorizing officials for early resolution, as appropriate. The results of security 

control assessments carried out during system development and implementation can also be used (consistent with reuse 

criteria) during the security authorization process to avoid system fielding delays or costly repetition of assessments. 

The security assessment plan is reviewed and approved by appropriate organizational officials to ensure that the plan is 

consistent with the security objectives of the organization, employs state-of-the practice tools, techniques, procedures, 

and automation to support the concept of continuous monitoring and near real-time risk management, and is costeffective with regard to the resources allocated for the assessment. The purpose of the security assessment plan 

approval is two-fold: (i) to establish the appropriate expectations for the security control assessment; and (ii) to bound 

the level of effort for the security control assessment. An approved security assessment plan helps to ensure that an 

appropriate level of resources is applied toward determining security control effectiveness. When security controls are 

provided to an organization by an external provider (e.g., through contracts, interagency agreements, lines of business 

arrangements, licensing agreements, and/or supply chain arrangements), the organization obtains a security assessment 

plan from the provider.

Organizations consider both the technical expertise and level of independence required in selecting security control 

assessors. Organizations also ensure that security control assessors possess the required skills and technical expertise to 

successfully carry out assessments of system-specific, hybrid, and common controls. This includes knowledge of and 

experience with the specific hardware, software, and firmware components employed by the organization. An 

independent assessor is any individual or group capable of conducting an impartial assessment of security controls 

employed within or inherited by an information system. Impartiality implies that assessors are free from any perceived 

or actual conflicts of interest with respect to the development, operation, and/or management of the information system 

or the determination of security control effectiveness. Independent security control assessment services can be obtained 

from other elements within the organization or can be contracted to a public or private sector entity outside of the 

organization. Contracted assessment services are considered independent if the information system owner is not 

directly involved in the contracting process or cannot unduly influence the independence of the assessor(s) conducting 

the assessment of the security controls. The authorizing official or designated representative determines the required 

level of independence for security control assessors based on the results of the security categorization process for the 

information system and the ultimate risk to organizational operations and assets, individuals, other organizations, and 

the Nation. The authorizing official determines if the level of assessor independence is sufficient to provide confidence 

that the assessment results produced are sound and can be used to support a risk-based decision on whether to place the 

information system into operation or continue its operation. In special situations, for example when the organization 

that owns the information system is small or the organizational structure requires that the security control assessment 

be accomplished by individuals that are in the developmental, operational, and/or management chain of the system 

owner, independence in the assessment process can be achieved by ensuring that the assessment results are carefully 

reviewed and analyzed by an independent team of experts to validate the completeness, consistency, and veracity of the 

results. The authorizing official consults with the Office of the Inspector General, the senior information security 

officer, and the chief information officer to discuss the implications of any decisions on assessor independence in the 

types of special circumstances described above. This discussion may occur prior to each security assessment or only 

once if an organization is establishing an organizational policy and approach for specific special circumstances that will 

be applied to all information systems meeting the specific special circumstance criteria. Security control assessments in 

support of initial and subsequent security authorizations are conducted by independent assessors.

References: NIST Special Publication 800-53A.

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SECURITY CONTROL ASSESSMENT

TASK 4-2: Assess the security controls in accordance with the assessment procedures defined in the security 

assessment plan.

Primary Responsibility: Security Control Assessor.

Supporting Roles: Information System Owner or Common Control Provider; Information Owner/Steward; Information 

System Security Officer.

System Development Life Cycle Phase: Development/Acquisition; Implementation.

Supplemental Guidance: Security control assessments determine the extent to which the controls are implemented 

correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements 

for the information system. Security control assessments occur as early as practicable in the system development life 

cycle, preferably during the development phase of the information system. These types of assessments are referred to as 

developmental testing and evaluation and are intended to validate that the required security controls are implemented 

correctly and consistent with the established information security architecture. Developmental testing and evaluation 

activities include, for example, design and code reviews, application scanning, and regression testing. Security 

weaknesses and deficiencies identified early in the system development life cycle can be resolved more quickly and in 

a much more cost-effective manner before proceeding to subsequent phases in the life cycle. The objective is to 

identify the information security architecture and security controls up front and to ensure that the system design and 

testing validate the implementation of these controls.

The information system owner relies on the technical expertise and judgment of assessors to: (i) assess the security 

controls employed within or inherited by the information system using assessment procedures specified in the security 

assessment plan; and (ii) provide specific recommendations on how to correct weaknesses or deficiencies in the 

controls and reduce or eliminate identified vulnerabilities. The assessor findings are an unbiased, factual reporting of 

the weaknesses and deficiencies discovered during the security control assessment. Organizations are encouraged to 

maximize the use of automation to conduct security control assessments to help: (i) increase the speed and overall 

effectiveness and efficiency of the assessments; and (ii) support the concept of ongoing monitoring of the security state 

of organizational information systems. When iterative development processes such as agile development are employed, 

this typically results in an iterative assessment as each cycle is conducted. A similar process is used for assessing 

security controls in COTS information technology products employed within the information system. Even when 

iterative development is not employed, organizations may choose to begin assessing security controls prior to the 

complete implementation of all security controls listed in the security plan. This type of incremental assessment is 

appropriate if it is more efficient or cost-effective to do so. For example, policy, procedures, and plans may be assessed 

prior to the assessment of the technical security controls in the hardware and software. In many cases, common controls 

(i.e., security controls inherited by the information system) may be assessed prior to the security controls employed 

within the system.

The organization ensures that assessors have access to: (i) the information system and environment of operation where 

the security controls are employed; and (ii) the appropriate documentation, records, artifacts, test results, and other 

materials needed to assess the security controls. In addition, assessors have the required degree of independence as 

determined by the authorizing official (see Appendix D.13 and Appendix F.4). Security control assessments in support 

of initial and subsequent security authorizations are conducted by independent assessors. Assessor independence during 

continuous monitoring, although not mandated, facilitates reuse of assessment results when reauthorization is required. 

When security controls are provided to an organization by an external provider (e.g., through contracts, interagency 

agreements, lines of business arrangements, licensing agreements, and/or supply chain arrangements), the organization 

ensures that assessors have access to the information system/environment of operation where the controls are employed 

as well as appropriate information needed to carry out the assessment. The organization also obtains any information 

related to existing assessments that may have been conducted by the external provider and reuses such assessment 

information whenever possible in accordance with the reuse criteria established by the organization. Descriptive 

information about the information system is typically documented in the system identification section of the security 

plan or included by reference or as attachments to the plan. Supporting materials such as procedures, reports, logs, and 

records showing evidence of security control implementation are identified as well. In order to make the risk 

management process as timely and cost-effective as possible, the reuse of previous assessment results, when reasonable 

and appropriate, is strongly recommended. For example, a recent audit of an information system may have produced 

information about the effectiveness of selected security controls. Another opportunity to reuse previous assessment 

results comes from programs that test and evaluate the security features of commercial information technology 

products. Additionally, if prior assessment results from the system developer are available, the security control 

assessor, under appropriate circumstances, may incorporate those results into the assessment. And finally, assessment 

results are reused to support reciprocity where possible.

References: NIST Special Publication 800-53A.

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SECURITY ASSESSMENT REPORT

TASK 4-3: Prepare the security assessment report documenting the issues, findings, and recommendations 

from the security control assessment.

Primary Responsibility: Security Control Assessor.

Supporting Roles: Information System Owner or Common Control Provider; Information System Security Officer.

System Development Life Cycle Phase: Development/Acquisition; Implementation.

Supplemental Guidance: The results of the security control assessment, including recommendations for correcting any 

weaknesses or deficiencies in the controls, are documented in the security assessment report. The security assessment 

report is one of three key documents in the security authorization package developed for authorizing officials. The 

assessment report includes information from the assessor necessary to determine the effectiveness of the security 

controls employed within or inherited by the information system based upon the assessor’s findings. The security 

assessment report is an important factor in an authorizing official’s determination of risk to organizational operations 

and assets, individuals, other organizations, and the Nation. Security control assessment results are documented at a 

level of detail appropriate for the assessment in accordance with the reporting format prescribed by organizational 

and/or federal policies. The reporting format is also appropriate for the type of security control assessment conducted 

(e.g., developmental testing and evaluation, self-assessments, independent verification and validation, independent 

assessments supporting the security authorization process or subsequent reauthorizations, assessments during 

continuous monitoring, assessments subsequent to remediation actions, independent audits/evaluations).

Security control assessment results obtained during system development are brought forward in an interim report and 

included in the final security assessment report. This supports the concept that the security assessment report is an 

evolving document that includes assessment results from all relevant phases of the system development life cycle 

including the results generated during continuous monitoring. Organizations may choose to develop an executive 

summary from the detailed findings that are generated during a security control assessment. An executive summary 

provides an authorizing official with an abbreviated version of the assessment report focusing on the highlights of the 

assessment, synopsis of key findings, and/or recommendations for addressing weaknesses and deficiencies in the 

security controls.

References: NIST Special Publication 800-53A.

REMEDIATION ACTIONS

TASK 4-4: Conduct initial remediation actions on security controls based on the findings and

recommendations of the security assessment report and reassess remediated control(s), as appropriate.

Primary Responsibility: Information System Owner or Common Control Provider; Security Control Assessor.

Supporting Roles: Authorizing Official or Designated Representative; Chief Information Officer; Senior Information 

Security Officer; Information Owner/Steward; Information System Security Officer; Information System Security 

Engineer; Security Control Assessor.

System Development Life Cycle Phase: Development/Acquisition; Implementation.

Supplemental Guidance: The security assessment report provides visibility into specific weaknesses and deficiencies in 

the security controls employed within or inherited by the information system that could not reasonably be resolved 

during system development or that are discovered post-development. Such weaknesses and deficiencies are potential 

vulnerabilities if exploitable by a threat source. The findings generated during the security control assessment provide 

important information that facilitates a disciplined and structured approach to mitigating risks in accordance with 

organizational priorities. An updated assessment of risk (either formal or informal) based on the results of the findings 

produced during the security control assessment and any inputs from the risk executive (function), helps to determine 

the initial remediation actions and the prioritization of such actions. Information system owners and common control 

providers, in collaboration with selected organizational officials (e.g., information system security engineer, 

authorizing official designated representative, chief information officer, senior information security officer, information 

owner/steward), may decide, based on an initial or updated assessment of risk, that certain findings are inconsequential 

and present no significant risk to the organization. Alternatively, the organizational officials may decide that certain 

findings are in fact, significant, requiring immediate remediation actions. In all cases, organizations review assessor 

findings and determine the severity or seriousness of the findings (i.e., the potential adverse impact on organizational 

operations and assets, individuals, other organizations, or the Nation) and whether the findings are sufficiently 

significant to be worthy of further investigation or remediation. Senior leadership involvement in the mitigation process 

may be necessary in order to ensure that the organization’s resources are effectively allocated in accordance with 

organizational priorities, providing resources first to the information systems that are supporting the most critical and 

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sensitive missions and business functions for the organization or correcting the deficiencies that pose the greatest 

degree of risk. If weaknesses or deficiencies in security controls are corrected, the security control assessor reassesses 

the remediated controls for effectiveness. Security control reassessments determine the extent to which the remediated 

controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting 

the security requirements for the information system. Exercising caution not to change the original assessment results, 

assessors update the security assessment report with the findings from the reassessment. The security plan is updated 

based on the findings of the security control assessment and any remediation actions taken. The updated security plan 

reflects the actual state of the security controls after the initial assessment and any modifications by the information 

system owner or common control provider in addressing recommendations for corrective actions. At the completion of 

the assessment, the security plan contains an accurate list and description of the security controls implemented 

(including compensating controls) and a list of residual vulnerabilities.

Organizations can prepare an optional addendum to the security assessment report that is transmitted to the authorizing 

official. The optional addendum provides information system owners and common control providers an opportunity to 

respond to the initial findings of assessors. The addendum may include, for example, information regarding initial 

remediation actions taken by information system owners or common control providers in response to assessor findings, 

or provide an owner’s perspective on the findings (e.g., including additional explanatory material, rebutting certain 

findings, and correcting the record). The addendum to the security assessment report does not change or influence in 

any manner, the initial assessor findings provided in the original report. Information provided in the addendum is 

considered by authorizing officials in their risk-based authorization decisions. Organizations may choose to employ an 

issue resolution process to help determine the appropriate actions to take with regard to the security control weaknesses 

and deficiencies identified during the assessment. Issue resolution can help address vulnerabilities and associated risk, 

false positives, and other factors that may provide useful information to authorizing officials regarding the security 

state of the information system including the ongoing effectiveness of system-specific, hybrid, and common controls. 

The issue resolution process can also help to ensure that only substantive items are identified and transferred to the plan 

of actions and milestones.

References: NIST Special Publications 800-30, 800-53A.

Milestone Checkpoint #4

- Has the organization developed a comprehensive plan to assess the security controls employed within or inherited by the 

information system?

- Was the assessment plan reviewed and approved by appropriate organizational officials? 

- Has the organization considered the appropriate level of assessor independence for the security control assessment?

- Has the organization provided all of the essential supporting assessment-related materials needed by the assessor(s) to 

conduct an effective security control assessment?

- Has the organization examined opportunities for reusing assessment results from previous assessments or from other 

sources?

- Did the assessor(s) complete the security control assessment in accordance with the stated assessment plan?

- Did the organization receive the completed security assessment report with appropriate findings and recommendations 

from the assessor(s)?

- Did the organization take the necessary remediation actions to address the most important weaknesses and deficiencies 

in the information system and its environment of operation based on the findings and recommendations in the security 

assessment report?

- Did the assessor reassess the remediated controls for effectiveness to provide the authorization official with an unbiased, 

factual security assessment report on the weaknesses or deficiencies in the system?

- Did the organization update appropriate security plans based on the findings and recommendations in the security 

assessment report and any subsequent changes to the information system and its environment of operation?

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3.5 RMF STEP 5 – AUTHORIZE INFORMATION SYSTEM

PLAN OF ACTION AND MILESTONES

TASK 5-1: Prepare the plan of action and milestones based on the findings and recommendations of the 

security assessment report excluding any remediation actions taken.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Implementation.

Supplemental Guidance: The plan of action and milestones, prepared for the authorizing official by the information 

system owner or the common control provider, is one of three key documents in the security authorization package and 

describes the specific tasks that are planned: (i) to correct any weaknesses or deficiencies in the security controls noted 

during the assessment; and (ii) to address the residual vulnerabilities in the information system. The plan of action and 

milestones identifies: (i) the tasks to be accomplished with a recommendation for completion either before or after 

information system implementation; (ii) the resources required to accomplish the tasks; (iii) any milestones in meeting 

the tasks; and (iv) the scheduled completion dates for the milestones. The plan of action and milestones is used by the 

authorizing official to monitor progress in correcting weaknesses or deficiencies noted during the security control 

assessment. All security weaknesses and deficiencies identified during the security control assessment are documented 

in the security assessment report to maintain an effective audit trail. Organizations develop specific plans of action and 

milestones based on the results of the security control assessment and in accordance with applicable laws, Executive 

Orders, directives, policies, standards, guidance, or regulations. Plan of action and milestones entries are not required 

when weaknesses or deficiencies are remediated during the assessment or prior to the submission of the authorization 

package to the authorizing official.

Organizations define a strategy for developing plans of action and milestones that facilitates a prioritized approach to 

risk mitigation that is consistent across the organization. The strategy helps to ensure that organizational plans of action 

and milestones are based on: (i) the security categorization of the information system; (ii) the specific weaknesses or 

deficiencies in the security controls; (iii) the importance of the identified security control weaknesses or deficiencies 

(i.e., the direct or indirect effect the weaknesses or deficiencies may have on the overall security state of the 

information system, and hence on the risk exposure of the organization, or ability of the organization to perform its 

mission or business functions); and (iv) the organization’s proposed risk mitigation approach to address the identified 

weaknesses or deficiencies in the security controls (e.g., prioritization of risk mitigation actions, allocation of risk 

mitigation resources). A risk assessment guides the prioritization process for items included in the plan of action and 

milestones.

References: OMB Memorandum 02-01; NIST Special Publications 800-30, 800-53A.

SECURITY AUTHORIZATION PACKAGE

TASK 5-2: Assemble the security authorization package and submit the package to the authorizing official 

for adjudication.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Information System Security Officer; Security Control Assessor.

System Development Life Cycle Phase: Implementation.

Supplemental Guidance: The security authorization package contains: (i) the security plan; (ii) the security assessment 

report; and (iii) the plan of action and milestones. The information in these key documents is used by authorizing 

officials to make risk-based authorization decisions. For information systems inheriting common controls for specific 

security capabilities, the security authorization package for the common controls or a reference to such documentation 

is also included in the authorization package. When security controls are provided to an organization by an external 

provider (e.g., through contracts, interagency agreements, lines of business arrangements, licensing agreements, and/or 

supply chain arrangements), the organization ensures that the information needed for authorizing officials to make riskbased decisions, is made available by the provider.

Additional information can be included in the security authorization package at the request of the authorizing official 

carrying out the authorization action. The contents of the security authorization package are protected appropriately in 

accordance with federal and organizational policies. Organizations are strongly encouraged to use automated support 

tools in preparing and managing the content of the security authorization package to help provide an effective vehicle 

for maintaining and updating information for authorizing officials regarding the ongoing security status of information 

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systems within the organization. Providing orderly, disciplined, and timely updates to the security plan, security 

assessment report, and plan of action and milestones on an ongoing basis, supports the concept of near real-time risk 

management and ongoing authorization. It also facilitates more cost-effective and meaningful reauthorization actions, if 

required. Organizations maintain strict version control as key documents in the authorization package are updated. 

With the use of automated tools and supporting databases, authorizing officials and other senior leaders within the 

organization are able to maintain awareness with regard to the security state of the information system including the 

ongoing effectiveness of system-specific, hybrid, and common controls.

References: None.

RISK DETERMINATION

TASK 5-3: Determine the risk to organizational operations (including mission, functions, image, or 

reputation), organizational assets, individuals, other organizations, or the Nation.

Primary Responsibility: Authorizing Official or Designated Representative.

Supporting Roles: Risk Executive (Function); Senior Information Security Officer.

System Development Life Cycle Phase: Implementation.

Supplemental Guidance: The authorizing official or designated representative, in collaboration with the senior 

information security officer, assesses the information provided by the information system owner or common control 

provider regarding the current security state of the system or the common controls inherited by the system and the 

recommendations for addressing any residual risks. Risk assessments (either formal or informal) are employed at the 

discretion of the organization to provide needed information on threats, vulnerabilities, and potential impacts as well as 

the analyses for the risk mitigation recommendations. The risk executive (function) also provides information to the

authorizing official that is considered in the final determination of risk to organizational operations and assets, 

individuals, other organizations, and the Nation resulting from the operation and use of the information system. Riskrelated information includes the criticality of organizational missions and/or business functions supported by the 

information system and the risk management strategy for the organization. The risk management strategy typically 

describes: (i) how risk is assessed within the organization (i.e., tools, techniques, procedures, and methodologies); (ii) 

how assessed risks are evaluated with regard to severity or criticality; (iii) known existing aggregated risks from 

organizational information systems and other sources; (iv) risk response approaches; (v) organizational risk tolerance; 

and (vi) how risk is monitored over time. When making the final risk determination, the authorizing official or 

designated representative considers information obtained from the risk executive (function) and the information 

provided by the information system owner or common control provider in the security authorization package (i.e., 

security plan, security assessment report, and plan of action and milestones). Conversely, information system-related 

security risk information derived from the execution of the RMF is available to the risk executive (function) for use in 

formulating and updating the organization-wide risk management strategy. After risk determination, organizations can 

respond to risk in a variety of ways, including: (i) accepting risk; (ii) avoiding risk; (iii) mitigating risk; (iv) sharing 

risk; (v) transferring risk; or (vi) a combination of the above. Decisions on the most appropriate course of action for 

risk response include some form of prioritization. Some risks may be of greater concern than other risks. In that case, 

more resources may need to be directed at addressing higher-priority risks than at other lower-priority risks. This does 

not necessarily mean that the lower-priority risks are ignored. Rather, it could mean that fewer resources are directed at 

the lower-priority risks (at least initially), or that the lower-priority risks are addressed at a later time. A key part of the 

risk decision process is the recognition that regardless of the risk decision, there typically remains a degree of residual

risk. Organizations determine acceptable degrees of residual risk based on organizational risk tolerance. 

References: NIST Special Publications 800-30, 800-39.

RISK ACCEPTANCE

TASK 5-4: Determine if the risk to organizational operations, organizational assets, individuals, other 

organizations, or the Nation is acceptable.

Primary Responsibility: Authorizing Official.

Supporting Roles: Risk Executive (Function); Authorizing Official Designated Representative; Senior Information 

Security Officer.

System Development Life Cycle Phase: Implementation.

Supplemental Guidance: The explicit acceptance of risk is the responsibility of the authorizing official and cannot be 

delegated to other officials within the organization. The authorizing official considers many factors when deciding if 

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the risk to organizational operations (including mission, function, image, or reputation), organizational assets, 

individuals, other organizations, and the Nation, is acceptable. Balancing security considerations with mission and 

operational needs is paramount to achieving an acceptable authorization decision. The authorizing official issues an 

authorization decision for the information system and the common controls inherited by the system after reviewing all 

of the relevant information and, where appropriate, consulting with other organizational officials, including the 

organization’s risk executive (function). Security authorization decisions are based on the content of the security 

authorization package and, where appropriate, any inputs received from key organizational officials, including the risk 

executive (function). The authorization package provides relevant information on the security state of the information 

system including the ongoing effectiveness of the security controls employed within or inherited by the system. Inputs 

from the risk executive (function), including previously established overarching risk guidance to authorizing officials, 

provide additional organization-wide information to the authorizing official that may be relevant and affect the 

authorization decision (e.g., organizational risk tolerance, specific mission and business requirements, dependencies 

among information systems, and other types of risks not directly associated with the information system). Risk 

executive (function) inputs are documented and become part of the security authorization decision. Security 

authorization decisions, including inputs from the risk executive (function), are conveyed to information system owners 

and common control providers and made available to interested parties within the organization (e.g., information 

system owners and authorizing officials for interconnected systems, chief information officers, information 

owners/stewards, senior managers).

The authorization decision document conveys the final security authorization decision from the authorizing official to 

the information system owner or common control provider, and other organizational officials, as appropriate. The 

authorization decision document contains the following information: (i) authorization decision; (ii) terms and 

conditions for the authorization; and (iii) authorization termination date. The security authorization decision indicates 

to the information system owner whether the system is: (i) authorized to operate; or (ii) not authorized to operate. The 

terms and conditions for the authorization provide a description of any specific limitations or restrictions placed on the 

operation of the information system or inherited controls that must be followed by the system owner or common 

control provider. The authorization termination date, established by the authorizing official, indicates when the 

security authorization expires. Authorization termination dates are influenced by federal and/or organizational policies 

which may establish maximum authorization periods. Organizations may choose to eliminate the authorization 

termination date if the continuous monitoring program is sufficiently robust to provide the authorizing official with the 

needed information to conduct ongoing risk determination and risk acceptance activities with regard to the security 

state of the information system and the ongoing effectiveness of security controls employed within and inherited by the 

system.

If the security control assessments are conducted by qualified assessors with the required degree of independence based 

on federal/organizational policies, appropriate security standards and guidelines, and the needs of the authorizing 

official, the assessment results can be cumulatively applied to the reauthorization, thus supporting the concept of 

ongoing authorization. Organizational policies regarding ongoing authorization and formal reauthorization, if/when 

required, are consistent with federal directives, regulations, and/or policies.

The authorization decision document is attached to the original security authorization package containing the 

supporting documentation and transmitted to the information system owner or common control provider. Upon receipt 

of the authorization decision document and original authorization package, the information system owner or common 

control provider acknowledges and implements the terms and conditions of the authorization and notifies the 

authorizing official. The organization ensures that authorization documents for both information systems and for 

common controls are made available to appropriate organizational officials (e.g., information system owners inheriting 

common controls, risk executive (function), chief information officers, senior information security officers, information 

system security officers). Authorization documents, especially information dealing with information system 

vulnerabilities, are: (i) marked and appropriately protected in accordance with federal and organizational policies; and 

(ii) retained in accordance with the organization’s record retention policy. The authorizing official verifies, on an 

ongoing basis, that the terms and conditions established as part of the authorization are being followed by the 

information system owner or common control provider.

References: NIST Special Publication 800-39.

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Milestone Checkpoint #5

- Did the organization develop a plan of action and milestones reflecting organizational priorities for addressing the 

remaining weaknesses and deficiencies in the information system and its environment of operation?

- Did the organization develop an appropriate authorization package with all key documents including the security plan, 

security assessment report, and plan of action and milestones (if applicable)?

- Did the final risk determination and risk acceptance by the authorizing official reflect the risk management strategy 

developed by the organization and conveyed by the risk executive (function)?

- Was the authorization decision conveyed to appropriate organizational personnel including information system owners 

and common control providers?

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3.6 RMF STEP 6 – MONITOR SECURITY CONTROLS

INFORMATION SYSTEM AND ENVIRONMENT CHANGES

TASK 6-1: Determine the security impact of proposed or actual changes to the information system and its 

environment of operation.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Risk Executive (Function); Authorizing Official or Designated Representative; Senior Information 

Security Officer; Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Operation/Maintenance.

Supplemental Guidance: Information systems are in a constant state of change with upgrades to hardware, software, or 

firmware and modifications to the surrounding environments where the systems reside and operate. A disciplined and 

structured approach to managing, controlling, and documenting changes to an information system or its environment of 

operation is an essential element of an effective security control monitoring program. Strict configuration management 

and control processes are established by the organization to support such monitoring activities. It is important to record 

any relevant information about specific changes to hardware, software, or firmware such as version or release numbers, 

descriptions of new or modified features/capabilities, and security implementation guidance. It is also important to 

record any changes to the environment of operation for the information system (e.g., modifications to hosting networks 

and facilities, mission/business use of the system, threats), or changes to the organizational risk management strategy. 

The information system owner and common control provider use this information in assessing the potential security 

impact of the changes. Documenting proposed or actual changes to an information system or its environment of 

operation and subsequently assessing the potential impact those changes may have on the security state of the system or 

the organization is an important aspect of security control monitoring and maintaining the security authorization over 

time. Information system changes are generally not undertaken prior to assessing the security impact of such changes. 

Organizations are encouraged to maximize the use of automation when managing changes to the information system or 

its environment of operation.

Security impact analysis conducted by the organization, determines the extent to which proposed or actual changes to 

the information system or its environment of operation can affect or have affected the security state of the system.

Changes to the information system or its environment of operation may affect the security controls currently in place 

(including system-specific, hybrid, and common controls), produce new vulnerabilities in the system, or generate 

requirements for new security controls that were not needed previously. If the results of the security impact analysis 

indicate that the proposed or actual changes can affect or have affected the security state of the system, corrective 

actions are initiated and appropriate documents revised and updated (e.g., the security plan, security assessment report, 

and plan of action and milestones). The information system owner or common control provider consults with 

appropriate organizational officials/entities (e.g., configuration control board, senior information security officer, 

information system security officer) prior to implementing any security-related changes to the information system or its 

environment of operation. The authorizing official or designated representative uses the revised and updated security 

assessment report in collaboration with the senior information security officer and risk executive (function) to 

determine if a formal reauthorization action is necessary. Most routine changes to an information system or its 

environment of operation can be handled by the organization’s continuous monitoring program, thus supporting the 

concept of ongoing authorization and near real-time risk management. Conducting security impact analyses is part of 

an ongoing assessment of risk. As risk assessments are updated and refined, organizations use the results to modify

security plans based on the most recent threat and vulnerability information available. Updated risk assessments

provide a foundation for prioritizing/planning risk responses. The authorizing official or designated representative, in 

collaboration with the risk executive (function), confirms as needed, determinations of residual risk. The risk executive 

(function) notifies the authorizing official of any significant changes in the organizational risk posture.

References: NIST Special Publications 800-30, 800-53A.

ONGOING SECURITY CONTROL ASSESSMENTS

TASK 6-2: Assess the technical, management, and operational security controls employed within and 

inherited by the information system in accordance with the organization-defined monitoring strategy.

Primary Responsibility: Security Control Assessor.

Supporting Roles: Authorizing Official or Designated Representative; Information System Owner or Common Control 

Provider; Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Operation/Maintenance.

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Supplemental Guidance: Subsequent to the initial authorization (i.e., during continuous monitoring), the organization 

assesses all security controls (including management, operational, and technical controls) employed within and 

inherited by the information system on an ongoing basis. The frequency of monitoring is based on the monitoring 

strategy developed by the information system owner or common control provider and approved by the authorizing 

official and senior information security officer. For ongoing security control assessments, assessors have the required 

degree of independence as determined by the authorizing official (see Appendix D.13 and Appendix F.4). Security 

control assessments in support of initial and subsequent security authorizations are conducted by independent assessors. 

Assessor independence during continuous monitoring, although not mandated, introduces efficiencies into the process 

and allows for reuse of assessment results in support of ongoing authorization and when reauthorization is required.

Organizations can use the current year’s assessment results to meet the annual FISMA security control assessment 

requirement. To satisfy this requirement, organizations can draw upon the assessment results from any of the following 

sources, including but not limited to: (i) security control assessments conducted as part of an information system 

authorization, ongoing authorization, or formal reauthorization, if required; (ii) continuous monitoring activities; or (iii)

testing and evaluation of the information system as part of the system development life cycle process or audit (provided 

that the testing, evaluation, or audit results are current, relevant to the determination of security control effectiveness, 

and obtained by assessors with the required degree of independence). Existing security assessment results are reused to 

the extent that they are still valid and are supplemented with additional assessments as needed. Reuse of assessment 

information is critical in achieving a cost-effective, fully integrated security program capable of producing the needed 

evidence to determine the security status of the information system. The use of automation to support security control 

assessments facilitates a greater frequency and volume of assessments that is consistent with the monitoring strategy 

established by the organization.

References: NIST Special Publications 800-53A, 800-137.

ONGOING REMEDIATION ACTIONS

TASK 6-3: Conduct remediation actions based on the results of ongoing monitoring activities, assessment of 

risk, and outstanding items in the plan of action and milestones.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Authorizing Official or Designated Representative; Information Owner/Steward; Information 

System Security Officer; Information System Security Engineer; Security Control Assessor.

System Development Life Cycle Phase: Operation/Maintenance.

Supplemental Guidance: The assessment information produced by an assessor during continuous monitoring is 

provided to the information system owner and common control provider in an updated security assessment report. The 

information system owner and common control provider initiate remediation actions on outstanding items listed in the 

plan of actions and milestones and findings produced during the ongoing monitoring of security controls. The security 

control assessor may provide recommendations as to appropriate remediation actions. An assessment of risk (either 

formal or informal) informs organizational decisions with regard to conducting ongoing remediation actions. Security 

controls that are modified, enhanced, or added during the continuous monitoring process are reassessed by the assessor 

to ensure that appropriate corrective actions are taken to eliminate weaknesses or deficiencies or to mitigate the 

identified risk.

References: NIST Special Publications 800-30, 800-53, 800-53A; CNSS Instruction 1253.

KEY UPDATES

TASK 6-4: Update the security plan, security assessment report, and plan of action and milestones based on 

the results of the continuous monitoring process.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Operation/Maintenance.

Supplemental Guidance: To facilitate the near real-time management of risk associated with the operation and use of 

the information system, the organization updates the security plan, security assessment report, and plan of action and 

milestones on an ongoing basis. The updated security plan reflects any modifications to security controls based on risk 

mitigation activities carried out by the information system owner or common control provider. The updated security 

assessment report reflects additional assessment activities carried out to determine security control effectiveness based 

on modifications to the security plan and deployed controls. The updated plan of action and milestones: (i) reports 

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progress made on the current outstanding items listed in the plan; (ii) addresses vulnerabilities discovered during the 

security impact analysis or security control monitoring; and (iii) describes how the information system owner or 

common control provider intends to address those vulnerabilities. The information provided by these key updates helps 

to raise awareness of the current security state of the information system (and the common controls inherited by the 

system) thereby supporting the process of ongoing authorization and near real-time risk management.

The frequency of updates to risk management-related information is at the discretion of the information system owner, 

common control provider, and authorizing officials in accordance with federal and organizational policies. Updates to 

information regarding the security state of the information system (and common controls inherited by the system) are 

accurate and timely since the information provided influences ongoing security-related actions and decisions by 

authorizing officials and other senior leaders within the organization. With the use of automated support tools and 

effective organization-wide security program management practices, authorizing officials are able to readily access the 

current security state of the information system including the ongoing effectiveness of system-specific, hybrid, and 

common controls. This facilitates near real-time management of risk to organizational operations and assets, 

individuals, other organizations, and the Nation, and provides essential information for continuous monitoring and 

ongoing authorization.

When updating key information in security plans, security assessment reports, and plans of action and milestones, 

organizations ensure that the original information needed for oversight, management, and auditing purposes is not 

modified or destroyed. Providing an effective method of tracking changes to information over time through strict 

configuration management and control procedures (including version control) is necessary to: (i) achieve transparency 

in the information security activities of the organization; (ii) obtain individual accountability for security-related 

actions; and (iii) better understand emerging trends in the organization’s information security program.

References: NIST Special Publication 800-53A.

SECURITY STATUS REPORTING

TASK 6-5: Report the security status of the information system (including the effectiveness of security 

controls employed within and inherited by the system) to the authorizing official and other appropriate 

organizational officials on an ongoing basis in accordance with the monitoring strategy.

Primary Responsibility: Information System Owner or Common Control Provider.

Supporting Roles: Information System Security Officer.

System Development Life Cycle Phase: Operation/Maintenance.

Supplemental Guidance: The results of monitoring activities are recorded and reported to the authorizing official on an 

ongoing basis in accordance with the monitoring strategy. Security status reporting can be: (i) event-driven (e.g., when 

the information system or its environment of operation changes or the system is compromised or breached); (ii) timedriven (e.g., weekly, monthly, quarterly); or (iii) both (event- and time-driven). Security status reports provide the 

authorizing official and other senior leaders within the organization, essential information with regard to the security 

state of the information system including the effectiveness of deployed security controls. Security status reports 

describe the ongoing monitoring activities employed by the information system owner or common control provider. 

Security status reports also address vulnerabilities in the information system and its environment of operation 

discovered during the security control assessment, security impact analysis, and security control monitoring and how 

the information system owner or common control provider intends to address those vulnerabilities.

Organizations have significant latitude and flexibility in the breadth, depth, and formality of security status reports.

Security status reports can take whatever form the organization deems most appropriate. The goal is cost-effective and 

efficient ongoing communication with senior leaders conveying the current security state of the information system and 

its environment of operation with regard to organizational missions and business functions. At a minimum, security 

status reports summarize key changes to security plans, security assessment reports, and plans of action and milestones. 

Use of automated management tools facilitates the effectiveness and timeliness of security status reporting.

The frequency of security status reports is at the discretion of the organization and in accordance with federal and 

organizational policies. Status reports occur at appropriate intervals to transmit significant security-related information 

about the information system (including information regarding the ongoing effectiveness of security controls employed 

within and inherited by the system), but not so frequently as to generate unnecessary work. The authorizing official 

uses the security status reports in collaboration with the senior information security officer and risk executive (function) 

to determine if a formal reauthorization action is necessary. Security status reports are appropriately marked, protected, 

and handled in accordance with federal and organizational policies. At the discretion of the organization, security status 

reports can be used to help satisfy FISMA reporting requirements for documenting remedial actions for any securityrelated weaknesses or deficiencies. Note that this status reporting is intended to be ongoing, not to be interpreted as 

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requiring the time, expense, and formality associated with the information provided for the initial approval to operate. 

Rather, the reporting is conducted in the most cost-effective manner consistent with achieving the reporting objectives.

References: NIST Special Publication 800-53A.

ONGOING RISK DETERMINATION AND ACCEPTANCE

TASK 6-6: Review the reported security status of the information system (including the effectiveness of 

security controls employed within and inherited by the system) on an ongoing basis in accordance with the 

monitoring strategy to determine whether the risk to organizational operations, organizational assets, 

individuals, other organizations, or the Nation remains acceptable.

Primary Responsibility: Authorizing Official.

Supporting Roles: Risk Executive (Function); Authorizing Official Designated Representative; Senior Information 

Security Officer.

System Development Life Cycle Phase: Operation/Maintenance.

Supplemental Guidance: The authorizing official or designated representative reviews the reported security status of 

the information system (including the effectiveness of deployed security controls) on an ongoing basis, to determine the 

current risk to organizational operations and assets, individuals, other organizations, or the Nation. The authorizing 

official determines, with inputs as appropriate from the authorizing official designated representative, senior 

information security officer, and the risk executive (function), whether the current risk is acceptable and forwards 

appropriate direction to the information system owner or common control provider. The use of automated support tools 

to capture, organize, quantify, visually display, and maintain security status information promotes the concept of near 

real-time risk management regarding the overall risk posture of the organization. The use of metrics and dashboards 

increases an organization’s ability to make risk-based decisions by consolidating data from automated tools and 

providing it to decision makers at different levels within the organization in an easy-to-understand format. The risks 

being incurred may change over time based on the information provided in the security status reports. Determining how 

the changing conditions affect the mission or business risks associated with the information system is essential for 

maintaining adequate security. By carrying out ongoing risk determination and risk acceptance, authorizing officials 

can maintain the security authorization over time. Formal reauthorization actions, if required, occur only in accordance 

with federal or organizational policies. The authorizing official conveys updated risk determination and acceptance 

results to the risk executive (function).

References: NIST Special Publications 800-30, 800-39.

INFORMATION SYSTEM REMOVAL AND DISPOSAL

TASK 6-7: Implement an information system disposal strategy, when needed, which executes required 

actions when a system is removed from service.

Primary Responsibility: Information System Owner.

Supporting Roles: Risk Executive (Function); Authorizing Official Designated Representative; Senior Information 

Security Officer; Information Owner/Steward; Information System Security Officer.

System Development Life Cycle Phase: Disposal.

Supplemental Guidance: When a federal information system is removed from operation, a number of risk managementrelated actions are required. Organizations ensure that all security controls addressing information system removal and 

disposal (e.g., media sanitization, configuration management and control) are implemented. Organizational tracking 

and management systems (including inventory systems) are updated to indicate the specific information system 

components that are being removed from service. Security status reports reflect the new status of the information 

system. Users and application owners hosted on the decommissioned information system are notified as appropriate, 

and any security control inheritance relationships are reviewed and assessed for impact. This task also applies to 

subsystems that are removed from information systems or decommissioned. The effects of the subsystem removal or 

disposal are assessed with respect to the overall operation of the information system where the subsystem resided, or in 

the case of dynamic subsystems, the information systems where the subsystems were actively employed.

References: NIST Special Publications 800-30, 800-53A.

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Milestone Checkpoint #6

- Is the organization effectively monitoring changes to the information system and its environment of operation including 

the effectiveness of deployed security controls in accordance with the continuous monitoring strategy?

- Is the organization effectively analyzing the security impacts of identified changes to the information system and its 

environment of operation?

- Is the organization conducting ongoing assessments of security controls in accordance with the monitoring strategy?

- Is the organization taking the necessary remediation actions on an ongoing basis to address identified weaknesses and 

deficiencies in the information system and its environment of operation?

- Does the organization have an effective process in place to report the security status of the information system and its 

environment of operation to the authorizing officials and other designated senior leaders within the organization on an 

ongoing basis?

- Is the organization updating critical risk management documents based on ongoing monitoring activities?

- Are authorizing officials conducting ongoing security authorizations by employing effective continuous monitoring 

activities and communicating updated risk determination and acceptance decisions to information system owners and 

common control providers?

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APPENDIX A

REFERENCES

LAWS, POLICIES, DIRECTIVES, INSTRUCTIONS, STANDARDS, AND GUIDELINES

LEGISLATION

1. E-Government Act [includes FISMA] (P.L. 107-347), December 2002.

2. Federal Information Security Management Act (P.L. 107-347, Title III), December 2002. 

3. Paperwork Reduction Act (P.L. 104-13), May 1995.

POLICIES, DIRECTIVES, INSTRUCTIONS

1. Committee on National Security Systems (CNSS) Instruction 4009, National Information 

Assurance Glossary, June 2006.

2. Committee on National Security Systems (CNSS) Instruction 1253, Security 

Categorization and Control Selection for National Security Systems, October 2009.

3. Office of Management and Budget, Circular A-130, Appendix III, Transmittal 

Memorandum #4, Management of Federal Information Resources, November 2000.

4. Office of Management and Budget Memorandum M-02-01, Guidance for Preparing and 

Submitting Security Plans of Action and Milestones, October 2001.

STANDARDS

1. National Institute of Standards and Technology Federal Information Processing 

Standards Publication 199, Standards for Security Categorization of Federal Information 

and Information Systems, February 2004.

2. National Institute of Standards and Technology Federal Information Processing 

Standards Publication 200, Minimum Security Requirements for Federal Information and 

Information Systems, March 2006.

GUIDELINES

1. National Institute of Standards and Technology Special Publication 800-18, Revision 1, 

Guide for Developing Security Plans for Federal Information Systems, February 2006.

2. National Institute of Standards and Technology Special Publication 800-27, Revision A, 

Engineering Principles for Information Technology Security (A Baseline for Achieving 

Security), June 2004.

3. National Institute of Standards and Technology Special Publication 800-30, Risk 

Management Guide for Information Technology Systems, July 2002.

4. National Institute of Standards and Technology Special Publication 800-39 (Second 

Public Draft), Managing Risk from Information Systems: An Organizational Perspective, 

April 2008.

5. National Institute of Standards and Technology Special Publication 800-53, Revision 3, 

Recommended Security Controls for Federal Information Systems and Organizations, 

August 2009.

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6. National Institute of Standards and Technology Special Publication 800-53A, Guide for 

Assessing the Security Controls in Federal Information Systems: Building Effective 

Security Assessment Plans, July 2008.

7. National Institute of Standards and Technology Special Publication 800-59, Guideline for 

Identifying an Information System as a National Security System, August 2003.

8. National Institute of Standards and Technology Special Publication 800-60, Revision 1, 

Guide for Mapping Types of Information and Information Systems to Security Categories, 

August 2008.

9. National Institute of Standards and Technology Special Publication 800-70, Revision 1, 

National Checklist Program for IT Products--Guidelines for Checklist Users and 

Developers, September 2009.

10. National Institute of Standards and Technology Special Publication 800-128, Guide for 

Security-Focused Configuration Management of Information Systems, August 2011.

11. National Institute of Standards and Technology Special Publication 800-137, Information 

Security Continuous Monitoring for Federal Information Systems and Organizations, 

September 2011.

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APPENDIX B

GLOSSARY

COMMON TERMS AND DEFINITIONS

Appendix B provides definitions for security terminology used within Special Publication 800-37. 

Unless specifically defined in this glossary, all terms used in this publication are consistent with 

the definitions contained in CNSS Instruction 4009, National Information Assurance Glossary.

Adequate Security 

[OMB Circular A-130, 

Appendix III]

Security commensurate with the risk and the magnitude of harm 

resulting from the loss, misuse, or unauthorized access to or 

modification of information. This includes assuring that systems 

and applications used by the agency operate effectively and 

provide appropriate confidentiality, integrity, and availability, 

through the use of cost-effective management, personnel, 

operational, and technical controls.

Agency See Executive Agency.

Allocation The process an organization employs to determine whether 

security controls are defined as system-specific, hybrid, or 

common.

The process an organization employs to assign security controls 

to specific information system components responsible for 

providing a particular security capability (e.g., router, server, 

remote sensor).

Application A software program hosted by an information system.

Assessment See Security Control Assessment.

Assessor See Security Control Assessor.

Assurance The grounds for confidence that the set of intended security 

controls in an information system are effective in their 

application.

Authorization

(to operate)

The official management decision given by a senior 

organizational official to authorize operation of an information 

system and to explicitly accept the risk to organizational 

operations (including mission, functions, image, or reputation), 

organizational assets, individuals, other organizations, and the 

Nation based on the implementation of an agreed-upon set of 

security controls.

Authorization Boundary All components of an information system to be authorized for 

operation by an authorizing official and excludes separately 

authorized systems, to which the information system is 

connected.

Authorize Processing See Authorization.

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Authorizing Official A senior (federal) official or executive with the authority to 

formally assume responsibility for operating an information 

system at an acceptable level of risk to organizational operations 

(including mission, functions, image, or reputation), 

organizational assets, individuals, other organizations, and the 

Nation.

Authorizing Official 

Designated Representative

An organizational official acting on behalf of an authorizing 

official in carrying out and coordinating the required activities 

associated with security authorization.

Availability

[44 U.S.C., Sec. 3542]

Ensuring timely and reliable access to and use of information. 

Chief Information Officer

[PL 104-106, Sec. 5125(b)]

Agency official responsible for:

(i) Providing advice and other assistance to the head of the 

executive agency and other senior management personnel of the 

agency to ensure that information technology is acquired and 

information resources are managed in a manner that is consistent 

with laws, Executive Orders, directives, policies, regulations, and 

priorities established by the head of the agency;

(ii) Developing, maintaining, and facilitating the implementation 

of a sound and integrated information technology architecture for 

the agency; and 

(iii) Promoting the effective and efficient design and operation of 

all major information resources management processes for the 

agency, including improvements to work processes of the agency.

Note: Organizations subordinate to federal agencies may use the term Chief 

Information Officer to denote individuals filling positions with similar security 

responsibilities to agency-level Chief Information Officers.

Chief Information Security 

Officer

See Senior Agency Information Security Officer.

Common Control A security control that is inherited by one or more organizational 

information systems. See Security Control Inheritance.

Common Control Provider An organizational official responsible for the development, 

implementation, assessment, and monitoring of common controls 

(i.e., security controls inherited by information systems).

Compensating Security 

Controls

The management, operational, and technical controls (i.e., 

safeguards or countermeasures) employed by an organization in 

lieu of the recommended controls in the low, moderate, or high 

baselines described in NIST Special Publication 800-53, that 

provide equivalent or comparable protection for an information 

system.

Confidentiality

[44 U.S.C., Sec. 3542]

Preserving authorized restrictions on information access and 

disclosure, including means for protecting personal privacy and 

proprietary information.

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Configuration Control

[CNSSI 4009]

Process for controlling modifications to hardware, firmware, 

software, and documentation to protect the information system 

against improper modifications before, during, and after system 

implementation.

Continuous Monitoring Maintaining ongoing awareness to support organizational risk 

decisions.

Controlled Interface A boundary with a set of mechanisms that enforces the security 

policies and controls the flow of information between 

interconnected information systems.

Countermeasures

[CNSSI 4009]

Actions, devices, procedures, techniques, or other measures that 

reduce the vulnerability of an information system. Synonymous 

with security controls and safeguards.

Cross Domain Solution A form of controlled interface that provides the ability to 

manually and/or automatically access and/or transfer information 

between different security domains.

Domain

[CNSSI 4009]

An environment or context that includes a set of system resources 

and a set of system entities that have the right to access the 

resources as defined by a common security policy, security 

model, or security architecture. See Security Domain.

Dynamic Subsystem A subsystem that is not continually present during the execution 

phase of an information system. Service-oriented architectures 

and cloud computing architectures are examples of architectures 

that employ dynamic subsystems.

Environment of Operation The physical surroundings in which an information system 

processes, stores, and transmits information.

Executive Agency

[41 U.S.C., Sec. 403]

An executive department specified in 5 U.S.C., Sec. 101; a 

military department specified in 5 U.S.C., Sec. 102; an 

independent establishment as defined in 5 U.S.C., Sec. 104(1); 

and a wholly owned Government corporation fully subject to the 

provisions of 31 U.S.C., Chapter 91.

External Information 

System (or Component)

An information system or component of an information system 

that is outside of the authorization boundary established by the 

organization and for which the organization typically has no 

direct control over the application of required security controls or 

the assessment of security control effectiveness.

External Information 

System Service

An information system service that is implemented outside of the 

authorization boundary of the organizational information system 

(i.e., a service that is used by, but not a part of, the organizational 

information system) and for which the organization typically has 

no direct control over the application of required security controls 

or the assessment of security control effectiveness.

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External Information 

System Service Provider 

A provider of external information system services to an 

organization through a variety of consumer-producer 

relationships including but not limited to: joint ventures; business 

partnerships; outsourcing arrangements (i.e., through contracts, 

interagency agreements, lines of business arrangements); 

licensing agreements; and/or supply chain arrangements.

Federal Agency See Executive Agency.

Federal Information

System

[40 U.S.C., Sec. 11331]

An information system used or operated by an executive agency, 

by a contractor of an executive agency, or by another 

organization on behalf of an executive agency.

High-Impact System

[FIPS 200]

An information system in which at least one security objective 

(i.e., confidentiality, integrity, or availability) is assigned a FIPS 

199 potential impact value of high.

Hybrid Security Control A security control that is implemented in an information system 

in part as a common control and in part as a system-specific 

control.

See Common Control and System-Specific Security Control.

Information

[FIPS 199]

An instance of an information type.

Information Owner

[CNSSI 4009]

Official with statutory or operational authority for specified 

information and responsibility for establishing the controls for its 

generation, collection, processing, dissemination, and disposal.

Information Resources

[44 U.S.C., Sec. 3502]

Information and related resources, such as personnel, equipment, 

funds, and information technology.

Information Security

[44 U.S.C., Sec. 3542]

The protection of information and information systems from 

unauthorized access, use, disclosure, disruption, modification, or 

destruction in order to provide confidentiality, integrity, and 

availability.

Information Security 

Architect

Individual, group, or organization responsible for ensuring that 

the information security requirements necessary to protect the 

organization’s core missions and business processes are 

adequately addressed in all aspects of enterprise architecture 

including reference models, segment and solution architectures, 

and the resulting information systems supporting those missions 

and business processes.

Information Security

Policy

[CNSSI 4009]

Aggregate of directives, regulations, rules, and practices that 

prescribes how an organization manages, protects, and distributes 

information.

Information Security 

Program Plan

Formal document that provides an overview of the security 

requirements for an organization-wide information security 

program and describes the program management controls and 

common controls in place or planned for meeting those 

requirements.

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Information Steward Individual or group that helps to ensure the careful and 

responsible management of federal information belonging to the 

Nation as a whole, regardless of the entity or source that may 

have originated, created, or compiled the information. 

Information stewards provide maximum access to federal 

information to elements of the federal government and its 

customers, balanced by the obligation to protect the information 

in accordance with the provisions of FISMA and any associated 

security-related federal policies, directives, regulations, standards, 

and guidance.

Information System

[44 U.S.C., Sec. 3502]

A discrete set of information resources organized for the 

collection, processing, maintenance, use, sharing, dissemination, 

or disposition of information.

Information System 

Boundary

See Authorization Boundary.

Information System Owner

(or Program Manager)

Official responsible for the overall procurement, development, 

integration, modification, or operation and maintenance of an 

information system.

Information System 

Security Engineer

Individual assigned responsibility for conducting information 

system security engineering activities.

Information System 

Security Engineering

Process that captures and refines information security 

requirements and ensures their integration into information 

technology component products and information systems through 

purposeful security design or configuration.

Information Systemrelated Security RisksInformation system-related security risks are those risks that arise 

through the loss of confidentiality, integrity, or availability of 

information or information systems and consider impacts to the 

organization (including assets, mission, functions, image, or 

reputation), individuals, other organizations, and the Nation.

See Risk.

Information System

Security Officer

[CNSSI 4009]

Individual with assigned responsibility for maintaining the 

appropriate operational security posture for an information 

system or program.

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Information Technology

[40 U.S.C., Sec. 1401]

Any equipment or interconnected system or subsystem of 

equipment that is used in the automatic acquisition, storage, 

manipulation, management, movement, control, display, 

switching, interchange, transmission, or reception of data or 

information by the executive agency. For purposes of the 

preceding sentence, equipment is used by an executive agency if 

the equipment is used by the executive agency directly or is used 

by a contractor under a contract with the executive agency which: 

(i) requires the use of such equipment; or (ii) requires the use, to a 

significant extent, of such equipment in the performance of a 

service or the furnishing of a product. The term information

technology includes computers, ancillary equipment, software, 

firmware, and similar procedures, services (including support 

services), and related resources.

Information Type

[FIPS 199]

A specific category of information (e.g., privacy, medical, 

proprietary, financial, investigative, contractor sensitive, security 

management) defined by an organization or in some instances, by 

a specific law, Executive Order, directive, policy, or regulation.

Integrity

[44 U.S.C., Sec. 3542]

Guarding against improper information modification or 

destruction, and includes ensuring information non-repudiation 

and authenticity.

Joint Authorization Security authorization involving multiple authorizing officials.

Low-Impact System

[FIPS 200]

An information system in which all three security objectives (i.e., 

confidentiality, integrity, and availability) are assigned a FIPS 

199 potential impact value of low.

Management Controls

[FIPS 200]

The security controls (i.e., safeguards or countermeasures) for an 

information system that focus on the management of risk and the 

management of information system security.

Moderate-Impact System

[FIPS 200]

An information system in which at least one security objective 

(i.e., confidentiality, integrity, or availability) is assigned a FIPS 

199 potential impact value of moderate, and no security objective 

is assigned a FIPS 199 potential impact value of high.

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National Security System

[44 U.S.C., Sec. 3542]

Any information system (including any telecommunications 

system) used or operated by an agency or by a contractor of an 

agency, or other organization on behalf of an agency—(i) the 

function, operation, or use of which involves intelligence 

activities; involves cryptologic activities related to national 

security; involves command and control of military forces; 

involves equipment that is an integral part of a weapon or 

weapons system; or is critical to the direct fulfillment of military 

or intelligence missions (excluding a system that is to be used for 

routine administrative and business applications, for example, 

payroll, finance, logistics, and personnel management 

applications); or (ii) is protected at all times by procedures 

established for information that have been specifically authorized 

under criteria established by an Executive Order or an Act of 

Congress to be kept classified in the interest of national defense 

or foreign policy.

Net-centric Architecture A complex system of systems composed of subsystems and 

services that are part of a continuously evolving, complex 

community of people, devices, information and services 

interconnected by a network that enhances information sharing 

and collaboration. Subsystems and services may or may not be 

developed or owned by the same entity, and, in general, will not 

be continually present during the full life cycle of the system of 

systems. Examples of this architecture include service-oriented 

architectures and cloud computing architectures.

Operational Controls

[FIPS 200]

The security controls (i.e., safeguards or countermeasures) for an 

information system that are primarily implemented and executed 

by people (as opposed to systems).

Organization

[FIPS 200, Adapted]

An entity of any size, complexity, or positioning within an 

organizational structure (e.g., a federal agency or, as appropriate, 

any of its operational elements).

Plan of Action and

Milestones

[OMB Memorandum 02-01]

A document that identifies tasks needing to be accomplished. It 

details resources required to accomplish the elements of the plan, 

any milestones in meeting the tasks, and scheduled completion 

dates for the milestones.

Potential Impact

[FIPS 199]

The loss of confidentiality, integrity, or availability could be 

expected to have: (i) a limited adverse effect (FIPS 199 low); (ii) 

a serious adverse effect (FIPS 199 moderate); or (iii) a severe or 

catastrophic adverse effect (FIPS 199 high) on organizational 

operations, organizational assets, or individuals.

Reciprocity Mutual agreement among participating organizations to accept 

each other’s security assessments in order to reuse information 

system resources and/or to accept each other’s assessed security 

posture in order to share information.

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Risk

[FIPS 200, Adapted]

A measure of the extent to which an entity is threatened by a 

potential circumstance or event, and typically a function of: (i) 

the adverse impacts that would arise if the circumstance or event 

occurs; and (ii) the likelihood of occurrence.

[Note: Information system-related security risks are those risks that arise from 

the loss of confidentiality, integrity, or availability of information or information 

systems and reflect the potential adverse impacts to organizational operations 

(including mission, functions, image, or reputation), organizational assets, 

individuals, other organizations, and the Nation. Adverse impacts to the Nation 

include, for example, compromises to information systems that support critical 

infrastructure applications or are paramount to government continuity of 

operations as defined by the Department of Homeland Security.]

Risk Assessment The process of identifying risks to organizational operations 

(including mission, functions, image, reputation), organizational 

assets, individuals, other organizations, and the Nation, resulting 

from the operation of an information system.

Part of risk management, incorporates threat and vulnerability 

analyses, and considers mitigations provided by security controls 

planned or in place. Synonymous with risk analysis.

Risk Assessor

[NIST SP 800-30]

The individual, group, or organization responsible for conducting 

a risk assessment.

Risk Executive (Function) An individual or group within an organization that helps to ensure 

that: (i) security risk-related considerations for individual 

information systems, to include the authorization decisions, are 

viewed from an organization-wide perspective with regard to the 

overall strategic goals and objectives of the organization in 

carrying out its missions and business functions; and (ii) 

managing information system-related security risks is consistent 

across the organization, reflects organizational risk tolerance, and 

is considered along with other organizational risks affecting 

mission/business success.

Risk Management

[FIPS 200, Adapted]

The process of managing risks to organizational operations 

(including mission, functions, image, reputation), organizational 

assets, individuals, other organizations, and the Nation, resulting 

from the operation of an information system, and includes: (i) the 

conduct of a risk assessment; (ii) the implementation of a risk 

mitigation strategy; and (iii) employment of techniques and 

procedures for the continuous monitoring of the security state of 

the information system.

Safeguards

[CNSSI 4009]

Protective measures prescribed to meet the security requirements 

(i.e., confidentiality, integrity, and availability) specified for an 

information system. Safeguards may include security features, 

management constraints, personnel security, and security of 

physical structures, areas, and devices. Synonymous with security 

controls and countermeasures.

Security Authorization See Authorization. 

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Security Categorization The process of determining the security category for information 

or an information system. Security categorization methodologies 

are described in CNSS Instruction 1253 for national security 

systems and in FIPS 199 for other than national security systems.

Security Controls

[FIPS 199]

The management, operational, and technical controls (i.e., 

safeguards or countermeasures) prescribed for an information 

system to protect the confidentiality, integrity, and availability of 

the system and its information.

Security Control 

Assessment

The testing and/or evaluation of the management, operational, 

and technical security controls in an information system to 

determine the extent to which the controls are implemented 

correctly, operating as intended, and producing the desired 

outcome with respect to meeting the security requirements for the 

system.

Security Control Assessor The individual, group, or organization responsible for conducting 

a security control assessment.

Security Control 

Inheritance

A situation in which an information system or application 

receives protection from security controls (or portions of security 

controls) that are developed, implemented, assessed, authorized, 

and monitored by entities other than those responsible for the 

system or application; entities either internal or external to the 

organization where the system or application resides. See 

Common Control.

Security Domain

[CNSSI 4009]

A domain that implements a security policy and is administered 

by a single authority.

Security Impact Analysis The analysis conducted by an organizational official to determine 

the extent to which changes to the information system have 

affected the security state of the system.

Security Objective

[FIPS 199]

Confidentiality, integrity, or availability.

Security Plan Formal document that provides an overview of the security 

requirements for an information system or an information security 

program and describes the security controls in place or planned 

for meeting those requirements.

See System Security Plan or Information Security Program Plan.

Security Policy

[CNSSI 4009]

A set of criteria for the provision of security services.

Security Requirements

[FIPS 200]

Requirements levied on an information system that are derived 

from applicable laws, Executive Orders, directives, policies, 

standards, instructions, regulations, procedures, or organizational 

mission/business case needs to ensure the confidentiality, 

integrity, and availability of the information being processed, 

stored, or transmitted.

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Senior (Agency) 

Information Security 

Officer

[44 U.S.C., Sec. 3544]

Official responsible for carrying out the Chief Information 

Officer responsibilities under FISMA and serving as the Chief 

Information Officer’s primary liaison to the agency’s authorizing 

officials, information system owners, and information system 

security officers.

Note: Organizations subordinate to federal agencies may use the term Senior 

Information Security Officer or Chief Information Security Officer to denote 

individuals filling positions with similar responsibilities to Senior Agency 

Information Security Officers.

Senior Information 

Security Officer

See Senior Agency Information Security Officer.

Subsystem A major subdivision of an information system consisting of 

information, information technology, and personnel that performs 

one or more specific functions.

System See Information System.

System Security Plan

[NIST SP 800-18]

Formal document that provides an overview of the security 

requirements for an information system and describes the security 

controls in place or planned for meeting those requirements.

System-Specific Security 

Control

A security control for an information system that has not been 

designated as a common security control or the portion of a 

hybrid control that is to be implemented within an information 

system.

Tailored Security Control 

Baseline

A set of security controls resulting from the application of 

tailoring guidance to the security control baseline. See Tailoring.

Tailoring The process by which a security control baseline is modified 

based on: (i) the application of scoping guidance; (ii) the 

specification of compensating security controls, if needed; and 

(iii) the specification of organization-defined parameters in the 

security controls via explicit assignment and selection statements.

Technical Controls

[FIPS 200]

The security controls (i.e., safeguards or countermeasures) for an 

information system that are primarily implemented and executed 

by the information system through mechanisms contained in the 

hardware, software, or firmware components of the system.

Threat

[CNSSI 4009, Adapted]

Any circumstance or event with the potential to adversely impact 

organizational operations (including mission, functions, image, or 

reputation), organizational assets, individuals, other 

organizations, or the Nation through an information system via 

unauthorized access, destruction, disclosure, modification of 

information, and/or denial of service.

Threat Source

[FIPS 200]

The intent and method targeted at the intentional exploitation of a 

vulnerability or a situation and method that may accidentally 

trigger a vulnerability. Synonymous with threat agent.

Vulnerability

[CNSSI 4009]

Weakness in an information system, system security procedures, 

internal controls, or implementation that could be exploited or 

triggered by a threat source.

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Vulnerability Assessment

[CNSSI 4009]

Formal description and evaluation of the vulnerabilities in an 

information system.

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APPENDIX C

ACRONYMS

COMMON ABBREVIATIONS

CIO Chief Information Officer

CNSS Committee on National Security Systems

DoD Department of Defense

FIPS Federal Information Processing Standards

FISMA Federal Information Security Management Act

NIST National Institute of Standards and Technology

NSA National Security Agency

ODNI Office of the Director of National Intelligence

OMB Office of Management and Budget

RMF Risk Management Framework

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APPENDIX D

ROLES AND RESPONSIBILITIES

KEY PARTICIPANTS IN THE RISK MANAGEMENT PROCESS 

he following sections describe the roles and responsibilities of key participants involved in 

an organization’s risk management process.47 Recognizing that organizations have widely 

varying missions and organizational structures, there may be differences in naming 

conventions for risk management-related roles and how specific responsibilities are allocated 

among organizational personnel (e.g., multiple individuals filling a single role or one individual 

filling multiple roles).48 However, the basic functions remain the same. The application of the 

Risk Management Framework described in this publication is flexible, allowing organizations to 

effectively accomplish the intent of the specific tasks within their respective organizational 

structures to best manage information system-related security risks. Many risk management roles 

defined in this publication have counterpart roles defined in the routine system development life 

cycle processes carried out by organizations. Whenever possible, organizations align the risk 

management roles with similar (or complementary) roles defined for the system development life 

cycle.49

D.1 HEAD OF AGENCY (CHIEF EXECUTIVE OFFICER)

The head of agency (or chief executive officer) is the highest-level senior official or executive 

within an organization with the overall responsibility to provide information security protections 

commensurate with the risk and magnitude of harm (i.e., impact) to organizational operations and 

assets, individuals, other organizations, and the Nation resulting from unauthorized access, use, 

disclosure, disruption, modification, or destruction of: (i) information collected or maintained by 

or on behalf of the agency; and (ii) information systems used or operated by an agency or by a 

contractor of an agency or other organization on behalf of an agency. Agency heads are also 

responsible for ensuring that: (i) information security management processes are integrated with 

strategic and operational planning processes; (ii) senior officials within the organization provide 

information security for the information and information systems that support the operations and 

assets under their control; and (iii) the organization has trained personnel sufficient to assist in 

complying with the information security requirements in related legislation, policies, directives, 

instructions, standards, and guidelines. Through the development and implementation of strong 

policies, the head of agency establishes the organizational commitment to information security 

and the actions required to effectively manage risk and protect the core missions and business 

functions being carried out by the organization. The head of agency establishes appropriate 

accountability for information security and provides active support and oversight of monitoring 

and improvement for the information security program. Senior leadership commitment to 

information security establishes a level of due diligence within the organization that promotes a 

climate for mission and business success.

47 Organizations may define other roles (e.g., facilities manager, human resources manager, systems administrator) to 

support the risk management process.

48 Caution is exercised when one individual fills multiples roles in the risk management process to ensure that the 

individual retains an appropriate level of independence and remains free from conflicts of interest.

49 For example, the system development life cycle role of system developer or program manager can be aligned with 

information system owner; mission owner/manager can be aligned with authorizing official; and system/software 

engineers are complementary roles to information system security engineers.

T

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D.2 RISK EXECUTIVE (FUNCTION)

The risk executive (function) is an individual or group within an organization that helps to ensure 

that: (i) risk-related considerations for individual information systems, to include authorization 

decisions, are viewed from an organization-wide perspective with regard to the overall strategic 

goals and objectives of the organization in carrying out its core missions and business functions; 

and (ii) managing information system-related security risks is consistent across the organization, 

reflects organizational risk tolerance, and is considered along with other types of risks in order to 

ensure mission/business success. The risk executive (function) coordinates with the senior 

leadership of an organization to:

• Provide a comprehensive, organization-wide, holistic approach for addressing risk—an 

approach that provides a greater understanding of the integrated operations of the 

organization;

• Develop a risk management strategy for the organization providing a strategic view of 

information security-related risks with regard to the organization as a whole;50

• Facilitate the sharing of risk-related information among authorizing officials and other senior 

leaders within the organization;

• Provide oversight for all risk management-related activities across the organization (e.g., 

security categorizations) to help ensure consistent and effective risk acceptance decisions;

• Ensure that authorization decisions consider all factors necessary for mission and business 

success;

• Provide an organization-wide forum to consider all sources of risk (including aggregated risk) 

to organizational operations and assets, individuals, other organizations, and the Nation;

• Promote cooperation and collaboration among authorizing officials to include authorization 

actions requiring shared responsibility;

• Ensure that the shared responsibility for supporting organizational mission/business functions 

using external providers of information and services receives the needed visibility and is 

elevated to the appropriate decision-making authorities; and

• Identify the organizational risk posture based on the aggregated risk to information from the 

operation and use of the information systems for which the organization is responsible.

The risk executive (function) presumes neither a specific organizational structure nor formal 

responsibility assigned to any one individual or group within the organization. The head of the 

agency/organization may choose to retain the risk executive (function) or to delegate the function 

to another official or group (e.g., an executive leadership council). The risk executive (function) 

has inherent U.S. Government authority and is assigned to government personnel only.

D.3 CHIEF INFORMATION OFFICER

The chief information officer51 is an organizational official responsible for: (i) designating a 

senior information security officer; (ii) developing and maintaining information security policies, 

50 Authorizing officials may have narrow or localized perspectives in rendering authorization decisions, in some cases 

without fully understanding or explicitly accepting the risks being incurred from such decisions.

51 When an organization has not designated a formal chief information officer position, FISMA requires the associated 

responsibilities to be handled by a comparable organizational official.

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procedures, and control techniques to address all applicable requirements; (iii) overseeing 

personnel with significant responsibilities for information security and ensuring that the personnel 

are adequately trained; (iv) assisting senior organizational officials concerning their security 

responsibilities; and (v) in coordination with other senior officials, reporting annually to the head 

of the federal agency on the overall effectiveness of the organization’s information security 

program, including progress of remedial actions. The chief information officer, with the support 

of the risk executive (function) and the senior information security officer, works closely with 

authorizing officials and their designated representatives to help ensure that:

• An organization-wide information security program is effectively implemented resulting in 

adequate security for all organizational information systems and environments of operation 

for those systems;

• Information security considerations are integrated into programming/planning/budgeting 

cycles, enterprise architectures, and acquisition/system development life cycles;

• Information systems are covered by approved security plans and are authorized to operate;

• Information security-related activities required across the organization are accomplished in an 

efficient, cost-effective, and timely manner; and

• There is centralized reporting of appropriate information security-related activities.

The chief information officer and authorizing officials also determine, based on organizational 

priorities, the appropriate allocation of resources dedicated to the protection of the information 

systems supporting the organization's missions and business functions. For selected information 

systems, the chief information officer may be designated as an authorizing official or a coauthorizing official with other senior organizational officials. The role of chief information 

officer has inherent U.S. Government authority and is assigned to government personnel only.

D.4 INFORMATION OWNER/STEWARD

The information owner/steward is an organizational official with statutory, management, or 

operational authority for specified information and the responsibility for establishing the policies 

and procedures governing its generation, collection, processing, dissemination, and disposal.52 In 

information-sharing environments, the information owner/steward is responsible for establishing 

the rules for appropriate use and protection of the subject information (e.g., rules of behavior) and 

retains that responsibility even when the information is shared with or provided to other 

organizations. The owner/steward of the information processed, stored, or transmitted by an 

information system may or may not be the same as the system owner. A single information 

system may contain information from multiple information owners/stewards. Information 

owners/stewards provide input to information system owners regarding the security requirements 

and security controls for the systems where the information is processed, stored, or transmitted.

52 Federal information is an asset of the Nation, not of a particular federal agency or its subordinate organizations. In 

that spirit, many federal agencies are developing policies, procedures, processes, and training needed to end the practice 

of information ownership and implement the practice of information stewardship. Information stewardship is the 

careful and responsible management of federal information belonging to the Nation as a whole, regardless of the entity 

or source that may have originated, created, or compiled the information. Information stewards provide maximum 

access to federal information to elements of the federal government and its customers, balanced by the obligation to 

protect the information in accordance with the provisions of FISMA and any associated security-related federal 

policies, directives, regulations, standards, and guidance.

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D.5 SENIOR INFORMATION SECURITY OFFICER

The senior information security officer is an organizational official responsible for: (i) carrying 

out the chief information officer security responsibilities under FISMA; and (ii) serving as the 

primary liaison for the chief information officer to the organization’s authorizing officials, 

information system owners, common control providers, and information system security officers. 

The senior information security officer: (i) possesses professional qualifications, including 

training and experience, required to administer the information security program functions; (ii) 

maintains information security duties as a primary responsibility; and (iii) heads an office with 

the mission and resources to assist the organization in achieving more secure information and 

information systems in accordance with the requirements in FISMA. The senior information 

security officer (or supporting staff members) may also serve as authorizing official designated 

representatives or security control assessors. The role of senior information security officer has 

inherent U.S. Government authority and is assigned to government personnel only.

D.6 AUTHORIZING OFFICIAL

The authorizing official is a senior official or executive with the authority to formally assume 

responsibility for operating an information system at an acceptable level of risk to organizational 

operations and assets, individuals, other organizations, and the Nation.53 Authorizing officials 

typically have budgetary oversight for an information system or are responsible for the mission 

and/or business operations supported by the system. Through the security authorization process, 

authorizing officials are accountable for the security risks associated with information system 

operations. Accordingly, authorizing officials are in management positions with a level of 

authority commensurate with understanding and accepting such information system-related 

security risks. Authorizing officials also approve security plans, memorandums of agreement or 

understanding, and plans of action and milestones and determine whether significant changes in 

the information systems or environments of operation require reauthorization. Authorizing

officials can deny authorization to operate an information system or if the system is operational, 

halt operations, if unacceptable risks exist. Authorizing officials coordinate their activities with 

the risk executive (function), chief information officer, senior information security officer, 

common control providers, information system owners, information system security officers, 

security control assessors, and other interested parties during the security authorization process. 

With the increasing complexity of missions/business processes, partnership arrangements, and the 

use of external/shared services, it is possible that a particular information system may involve 

multiple authorizing officials. If so, agreements are established among the authorizing officials 

and documented in the security plan. Authorizing officials are responsible for ensuring that all 

activities and functions associated with security authorization that are delegated to authorizing 

official designated representatives are carried out. The role of authorizing official has inherent 

U.S. Government authority and is assigned to government personnel only.

D.7 AUTHORIZING OFFICIAL DESIGNATED REPRESENTATIVE

The authorizing official designated representative is an organizational official that acts on behalf 

of an authorizing official to coordinate and conduct the required day-to-day activities associated 

with the security authorization process. Authorizing official designated representatives can be 

empowered by authorizing officials to make certain decisions with regard to the planning and 

resourcing of the security authorization process, approval of the security plan, approval and 

monitoring the implementation of plans of action and milestones, and the assessment and/or 

53 The responsibility of authorizing officials described in FIPS 200, was extended in NIST Special Publication 800-53 

to include risks to other organizations and the Nation.

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determination of risk. The designated representative may also be called upon to prepare the final 

authorization package, obtain the authorizing official’s signature on the authorization decision 

document, and transmit the authorization package to appropriate organizational officials. The 

only activity that cannot be delegated to the designated representative by the authorizing official 

is the authorization decision and signing of the associated authorization decision document (i.e., 

the acceptance of risk to organizational operations and assets, individuals, other organizations, 

and the Nation).

D.8 COMMON CONTROL PROVIDER

The common control provider is an individual, group, or organization responsible for the 

development, implementation, assessment, and monitoring of common controls (i.e., security 

controls inherited by information systems).54 Common control providers are responsible for: (i) 

documenting the organization-identified common controls in a security plan (or equivalent 

document prescribed by the organization); (ii) ensuring that required assessments of common 

controls are carried out by qualified assessors with an appropriate level of independence defined 

by the organization; (iii) documenting assessment findings in a security assessment report; and 

(iv) producing a plan of action and milestones for all controls having weaknesses or deficiencies. 

Security plans, security assessment reports, and plans of action and milestones for common 

controls (or a summary of such information) is made available to information system owners 

inheriting those controls after the information is reviewed and approved by the senior official or 

executive with oversight responsibility for those controls.

D.9 INFORMATION SYSTEM OWNER

The information system owner is an organizational official responsible for the procurement, 

development, integration, modification, operation, maintenance, and disposal of an information 

system.55 The information system owner is responsible for addressing the operational interests of 

the user community (i.e., users who require access to the information system to satisfy mission, 

business, or operational requirements) and for ensuring compliance with information security 

requirements. In coordination with the information system security officer, the information 

system owner is responsible for the development and maintenance of the security plan and 

ensures that the system is deployed and operated in accordance with the agreed-upon security 

controls. In coordination with the information owner/steward, the information system owner is 

also responsible for deciding who has access to the system (and with what types of privileges or 

access rights)56 and ensures that system users and support personnel receive the requisite security 

training (e.g., instruction in rules of behavior). Based on guidance from the authorizing official, 

the information system owner informs appropriate organizational officials of the need to conduct 

the security authorization, ensures that the necessary resources are available for the effort, and 

provides the required information system access, information, and documentation to the security 

54 Organizations can have multiple common control providers depending on how information security responsibilities 

are allocated organization-wide. Common control providers may also be information system owners when the common 

controls are resident within an information system. Common controls are described in Section 2.4.

55 The information system owner serves as the focal point for the information system. In that capacity, the information 

system owner serves both as an owner and as the central point of contact between the authorization process and the 

owners of components of the system including, for example: (i) applications, networking, servers, or workstations; (ii) 

owners/stewards of information processed, stored, or transmitted by the system; and (iii) owners of the missions and 

business functions supported by the system. Some organizations may refer to information system owners as program 

managers or business/asset owners.

56 The responsibility for deciding who has access to specific information within an information system (and with what 

types of privileges or access rights) may reside with the information owner/steward.

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control assessor. The information system owner receives the security assessment results from the 

security control assessor. After taking appropriate steps to reduce or eliminate vulnerabilities, the 

information system owner assembles the authorization package and submits the package to the 

authorizing official or the authorizing official designated representative for adjudication.57

D.10 INFORMATION SYSTEM SECURITY OFFICER

The information system security officer58 is an individual responsible for ensuring that the 

appropriate operational security posture is maintained for an information system and as such, 

works in close collaboration with the information system owner. The information system security 

officer also serves as a principal advisor on all matters, technical and otherwise, involving the 

security of an information system. The information system security officer has the detailed 

knowledge and expertise required to manage the security aspects of an information system and, in 

many organizations, is assigned responsibility for the day-to-day security operations of a system. 

This responsibility may also include, but is not limited to, physical and environmental protection, 

personnel security, incident handling, and security training and awareness. The information 

system security officer may be called upon to assist in the development of the security policies 

and procedures and to ensure compliance with those policies and procedures. In close 

coordination with the information system owner, the information system security officer often 

plays an active role in the monitoring of a system and its environment of operation to include 

developing and updating the security plan, managing and controlling changes to the system, and 

assessing the security impact of those changes.

D.11 INFORMATION SECURITY ARCHITECT

The information security architect is an individual, group, or organization responsible for 

ensuring that the information security requirements necessary to protect the organization’s core 

missions and business processes are adequately addressed in all aspects of enterprise architecture 

including reference models, segment and solution architectures, and the resulting information 

systems supporting those missions and business processes. The information security architect 

serves as the liaison between the enterprise architect and the information system security engineer 

and also coordinates with information system owners, common control providers, and 

information system security officers on the allocation of security controls as system-specific, 

hybrid, or common controls. In addition, information security architects, in close coordination 

with information system security officers, advise authorizing officials, chief information officers, 

senior information security officers, and the risk executive (function), on a range of securityrelated issues including, for example, establishing information system boundaries, assessing the 

severity of weaknesses and deficiencies in the information system, plans of action and milestones, 

risk mitigation approaches, security alerts, and potential adverse effects of identified 

vulnerabilities.

57 Depending on how the organization has organized its security authorization activities, the authorizing official may 

choose to designate an individual other than the information system owner to compile and assemble the information for 

the security authorization package. In this situation, the designated individual must coordinate the compilation and 

assembly activities with the information system owner.

58 Organizations may also define an information system security manager or information security manager role with 

similar responsibilities as an information system security officer or with oversight responsibilities for an information 

security program. In these situations, information system security officers may, at the discretion of the organization, 

report directly to information system security managers or information security managers.

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D.12 INFORMATION SYSTEM SECURITY ENGINEER

The information system security engineer is an individual, group, or organization responsible for 

conducting information system security engineering activities. Information system security 

engineering is a process that captures and refines information security requirements and ensures 

that the requirements are effectively integrated into information technology component products 

and information systems through purposeful security architecting, design, development, and 

configuration. Information system security engineers are an integral part of the development team 

(e.g., integrated project team) designing and developing organizational information systems or 

upgrading legacy systems. Information system security engineers employ best practices when 

implementing security controls within an information system including software engineering 

methodologies, system/security engineering principles, secure design, secure architecture, and 

secure coding techniques. System security engineers coordinate their security-related activities 

with information security architects, senior information security officers, information system 

owners, common control providers, and information system security officers.

D.13 SECURITY CONTROL ASSESSOR

The security control assessor59 is an individual, group, or organization responsible for conducting 

a comprehensive assessment of the management, operational, and technical security controls and 

control enhancements employed within or inherited by an information system to determine the 

overall effectiveness of the controls (i.e., the extent to which the controls are implemented 

correctly, operating as intended, and producing the desired outcome with respect to meeting the 

security requirements for the system). Security control assessors also provide an assessment of 

the severity of weaknesses or deficiencies discovered in the information system and its 

environment of operation and recommend corrective actions to address identified vulnerabilities. 

In addition to the above responsibilities, security control assessors prepare the final security 

assessment report containing the results and findings from the assessment. Prior to initiating the 

security control assessment, an assessor conducts an assessment of the security plan to help 

ensure that the plan provides a set of security controls for the information system that meet the 

stated security requirements.

The required level of assessor independence is determined by the specific conditions of the 

security control assessment. For example, when the assessment is conducted in support of an 

authorization decision or ongoing authorization, the authorizing official makes an explicit 

determination of the degree of independence required in accordance with federal policies, 

directives, standards, and guidelines. Assessor independence is an important factor in: (i) 

preserving the impartial and unbiased nature of the assessment process; (ii) determining the 

credibility of the security assessment results; and (iii) ensuring that the authorizing official 

receives the most objective information possible in order to make an informed, risk-based, 

authorization decision. The information system owner and common control provider rely on the 

security expertise and the technical judgment of the assessor to: (i) assess the security controls 

employed within and inherited by the information system using assessment procedures specified 

in the security assessment plan; and (ii) provide specific recommendations on how to correct 

weaknesses or deficiencies in the controls and address identified vulnerabilities.

59 Security control assessors may be called certification agents in some organizations. At the discretion of the 

organization, security control assessors may be given additional duties/responsibilities for the post processing and 

analysis of security control assessment findings and results. This may include, for example, making specific 

determinations for or recommendations to authorizing officials (known in some communities of interest as certification 

recommendations or certification determinations).

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APPENDIX E

SUMMARY OF RMF TASKS

LISTING OF PRIMARY RESPONSIBILITIES AND SUPPORTING ROLES

RMF TASKS PRIMARY RESPONSIBILITY SUPPORTING ROLES

RMF Step 1: Categorize Information System

TASK 1-1

Security Categorization

Categorize the information system 

and document the results of the 

security categorization in the 

security plan.

Information System Owner

Information Owner/Steward

Risk Executive (Function)

Authorizing Official or Designated 

Representative

Chief Information Officer

Senior Information Security Officer

Information System Security Officer

TASK 1-2

Information System Description

Describe the information system 

(including system boundary) and 

document the description in the 

security plan.

Information System Owner Authorizing Official or Designated 

Representative

Senior Information Security Officer

Information Owner/Steward

Information System Security Officer

TASK 1-3

Information System Registration

Register the information system with 

appropriate organizational 

program/management offices.

Information System Owner Information System Security Officer

RMF Step 2: Select Security Controls

TASK 2-1

Common Control Identification

Identify the security controls that are 

provided by the organization as 

common controls for organizational 

information systems and document 

the controls in a security plan (or 

equivalent document).

Chief Information Officer or Senior 

Information Security Officer

Information Security Architect

Common Control Provider

Risk Executive (Function)

Authorizing Official or Designated 

Representative

Information System Owner

Information System Security Engineer

TASK 2-2

Security Control Selection

Select the security controls for the 

information system and document 

the controls in the security plan.

Information Security Architect

Information System Owner

Authorizing Official or Designated 

Representative

Information Owner/Steward

Information System Security Officer

Information System Security Engineer

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RMF TASKS PRIMARY RESPONSIBILITY SUPPORTING ROLES

TASK 2-3

Monitoring Strategy

Develop a strategy for the 

continuous monitoring of security 

control effectiveness and any 

proposed/actual changes to the 

information system and its 

environment of operation.

Information System Owner or Common 

Control Provider

Risk Executive (Function)

Authorizing Official or Designated 

Representative

Chief Information Officer

Senior Information Security Officer

Information Owner/Steward

Information System Security Officer

TASK 2-4

Security Plan Approval

Review and approve the security 

plan.

Authorizing Official or Designated 

Representative

Risk Executive (Function)

Chief Information Officer

Senior Information Security Officer

RMF Step 3: Implement Security Controls

TASK 3-1

Security Control Implementation

Implement the security controls 

specified in the security plan.

Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

Information System Security Engineer

TASK 3-2

Security Control Documentation

Document the security control 

implementation, as appropriate, in 

the security plan, providing a 

functional description of the control 

implementation (including planned 

inputs, expected behavior, and 

expected outputs).

Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

Information System Security Engineer

RMF Step 4: Assess Security Controls

TASK 4-1

Assessment Preparation

Develop, review, and approve a 

plan to assess the security controls.

Security Control Assessor Authorizing Official or Designated 

Representative

Chief Information Officer

Senior Information Security Officer

Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

TASK 4-2

Security Control Assessment

Assess the security controls in 

accordance with the assessment 

procedures defined in the security 

assessment plan.

Security Control Assessor Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

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RMF TASKS PRIMARY RESPONSIBILITY SUPPORTING ROLES

TASK 4-3

Security Assessment Report

Prepare the security assessment 

report documenting the issues, 

findings, and recommendations from 

the security control assessment.

Security Control Assessor Information System Owner or Common 

Control Provider

Information System Security Officer

TASK 4-4

Remediation Actions

Conduct initial remediation actions 

on security controls based on the 

findings and recommendations of 

the security assessment report and 

reassess remediated control(s), as 

appropriate.

Information System Owner or Common 

Control Provider

Security Control Assessor

Authorizing Official or Designated 

Representative

Chief Information Officer

Senior Information Security Officer

Information Owner/Steward

Information System Security Officer

Information System Security Engineer

RMF Step 5: Authorize Information System

TASK 5-1

Plan of Action and Milestones

Prepare the plan of action and 

milestones based on the findings 

and recommendations of the 

security assessment report 

excluding any remediation actions 

taken.

Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

TASK 5-2

Security Authorization Package

Assemble the security authorization 

package and submit the package to 

the authorizing official for 

adjudication.

Information System Owner or Common 

Control Provider

Information System Security Officer

Security Control Assessor

TASK 5-3

Risk Determination

Determine the risk to organizational 

operations (including mission, 

functions, image, or reputation), 

organizational assets, individuals, 

other organizations, or the Nation.

Authorizing Official or Designated 

Representative

Risk Executive (Function)

Senior Information Security Officer

TASK 5-4

Risk Acceptance

Determine if the risk to 

organizational operations, 

organizational assets, individuals, 

other organizations, or the Nation is 

acceptable.

Authorizing Official Risk Executive (Function)

Authorizing Official Designated 

Representative

Senior Information Security Officer

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RMF TASKS PRIMARY RESPONSIBILITY SUPPORTING ROLES

RMF Step 6: Monitor Security Controls

TASK 6-1

Information System and 

Environment Changes

Determine the security impact of 

proposed or actual changes to the 

information system and its 

environment of operation.

Information System Owner or Common 

Control Provider

Risk Executive (Function)

Authorizing Official or Designated 

Representative

Senior Information Security Officer

Information Owner/Steward

Information System Security Officer

TASK 6-2

Ongoing Security Control 

Assessments

Assess the technical, management, 

and operational security controls 

employed within and inherited by 

the information system in 

accordance with the organizationdefined monitoring strategy.

Security Control Assessor Authorizing Official or Designated 

Representative

Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

TASK 6-3

Ongoing Remediation Actions

Conduct remediation actions based 

on the results of ongoing monitoring 

activities, assessment of risk, and 

outstanding items in the plan of 

action and milestones.

Information System Owner or Common 

Control Provider

Authorizing Official or Designated 

Representative

Information Owner/Steward

Information System Security Officer

Information System Security Engineer

Security Control Assessor

TASK 6-4

Key Updates

Update the security plan, security 

assessment report, and plan of 

action and milestones based on the 

results of the continuous monitoring 

process.

Information System Owner or Common 

Control Provider

Information Owner/Steward

Information System Security Officer

TASK 6-5

Security Status Reporting

Report the security status of the 

information system (including the 

effectiveness of security controls 

employed within and inherited by 

the system) to the authorizing 

official and other appropriate 

organizational officials on an 

ongoing basis in accordance with 

the monitoring strategy.

Information System Owner or Common 

Control Provider

Information System Security Officer

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RMF TASKS PRIMARY RESPONSIBILITY SUPPORTING ROLES

TASK 6-6

Ongoing Risk Determination and 

Acceptance

Review the reported security status 

of the information system (including 

the effectiveness of security controls 

employed within and inherited by 

the system) on an ongoing basis in 

accordance with the monitoring 

strategy to determine whether the 

risk to organizational operations, 

organizational assets, individuals, 

other organizations, or the Nation 

remains acceptable.

Authorizing Official Risk Executive (Function)

Authorizing Official Designated 

Representative

Senior Information Security Officer

TASK 6-7

Information System Removal and 

Disposal

Implement an information system 

disposal strategy, when needed, 

which executes required actions 

when a system is removed from 

service.

Information System Owner Risk Executive (Function)

Authorizing Official Designated 

Representative

Senior Information Security Officer

Information Owner/Steward

Information System Security Officer

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APPENDIX F

SECURITY AUTHORIZATION

AUTHORIZATION DECISIONS AND SUPPORTING EVIDENCE

his appendix provides information on the security authorization process to include: (i) the 

content of the authorization package; (ii) types of authorization decisions; (iii) the content 

of the authorization decision document; and (iv) maintenance of authorizations through 

continuous monitoring processes and conditions for reauthorization.

F.1 AUTHORIZATION PACKAGE

The security authorization package documents the results of the security control assessment and 

provides the authorizing official with essential information needed to make a risk-based decision 

on whether to authorize operation of an information system or a designated set of common 

controls. Unless specifically designated otherwise by the chief information officer or authorizing 

official, the information system owner or common control provider is responsible for the 

assembly, compilation, and submission of the authorization package. The information system 

owner or common control provider receives inputs from the information system security officer, 

security control assessor, senior information security officer, and risk executive (function) during 

the preparation of the authorization package. The authorization package60 contains the following 

documents:

• Security plan;

• Security assessment report; and

• Plan of action and milestones.

The security plan, prepared by the information system owner or common control provider, 

provides an overview of the security requirements and describes the security controls in place or 

planned for meeting those requirements. The plan provides sufficient information to understand 

the intended or actual implementation of each security control employed within or inherited by 

the information system.

61 The security plan also contains as supporting appendices or as 

references to appropriate sources, other risk and security-related documents such as a risk 

assessment, privacy impact assessment, system interconnection agreements, contingency plan, 

security configurations, configuration management plan, incident response plan, and continuous 

monitoring strategy. In accordance with the near real-time risk management objectives of the 

security authorization process, the security plan is updated whenever events dictate changes to the 

security controls employed within or inherited by the information system. Updates to the security 

plan may be triggered by a variety of events, including for example: (i) a vulnerability scan of the 

information system or vulnerability assessment of the environment of operation; (ii) new threat 

information; (iii) weaknesses or deficiencies discovered in currently deployed security controls 

60 The authorizing official determines what additional supporting documentation or references may be required to be 

included in the security authorization package. Appropriate measures are employed to protect information contained in 

security authorization packages in accordance with federal and organizational policy.

61 The security plan is a conceptual body of information which may be accounted for within one or more repositories 

and include documents (electronic or hard copy) that come from a variety of sources produced throughout the system 

development life cycle. For example, information system owners inheriting common controls can either document the 

implementation of the controls in their respective security plans or reference the controls contained in the security plans 

of common control providers.

T

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after an information system breach; (iv) a redefinition of mission priorities or business objectives 

invalidating the results of the previous security categorization process; and (v) a change in the 

information system (e.g., adding new hardware, software, or firmware; establishing new 

connections) or its environment of operation (e.g., moving to a new facility).

The security assessment report, prepared by the security control assessor, provides the results of 

assessing the implementation of the security controls identified in the security plan to determine 

the extent to which the controls are implemented correctly, operating as intended, and producing 

the desired outcome with respect to meeting the specified security requirements. The security 

assessment report also contains a list of recommended corrective actions for any weaknesses or 

deficiencies identified in the security controls.62 Supporting the near real-time risk management 

objectives of the security authorization process, the security assessment report is updated on an 

ongoing basis whenever changes are made to the security controls employed within or inherited 

by the information system.63 Updates to the security assessment report help to ensure that the 

information system owner, common control provider, and authorizing officials maintain the 

appropriate awareness with regard to security control effectiveness. The overall effectiveness of 

the security controls directly affects the ultimate security state of the information system and 

decisions regarding explicit acceptance of risk.

The plan of action and milestones, prepared by the information system owner or common control 

provider, describes the specific measures planned: (i) to correct weaknesses or deficiencies noted 

in the security controls during the assessment; and (ii) to address known vulnerabilities in the 

information system.64 The content and structure of plans of action and milestones are informed by 

the organizational risk management strategy developed as part of the risk executive (function) 

and is consistent with the plans of action and milestones process established by the organization 

and any specific requirements defined in federal policies, directives, memoranda, or regulations. 

The most effective plans of action and milestones contain a robust set of actual weaknesses or 

deficiencies identified in the security controls employed within or inherited by the information 

system. Assuming that most information systems and the environments in which those systems 

are deployed, have more vulnerabilities than available resources can realistically address, 

organizations define a strategy for developing and implementing plans of action and milestones 

that facilitates a prioritized approach to risk mitigation and that is consistent across the 

organization. This strategy helps to ensure that plans of action and milestones are based on:

• The security categorization of the information system;

• The specific weaknesses or deficiencies in the security controls;

• The importance of the identified security control weaknesses or deficiencies (i.e., the direct or 

indirect effect the weaknesses or deficiencies may have on the overall security state of the 

information system and hence on the risk exposure65 of the organization);

62 Organizations may choose to develop an executive summary from the detailed findings that are generated during a 

security control assessment. An executive summary provides an authorizing official with an abbreviated version of the 

security assessment report focusing on the highlights of the assessment, synopsis of key findings, and recommendations 

for addressing weaknesses and deficiencies in the security controls.

63 Organizations maintain strict version control as critical documents in the authorization package are updated.

64 Organizations may choose to document the specific measures implemented to correct weaknesses or deficiencies in 

security controls in the plan of action and milestones, thereby providing an historical record of actions completed.

65 In general, risk exposure is the degree to which an organization is threatened by the potential adverse effects on 

organizational operations and assets, individuals, other organizations, or the Nation.

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• The organization’s proposed risk mitigation approach to address the identified weaknesses or 

deficiencies in the security controls (e.g., prioritization of risk mitigation actions, allocation 

of risk mitigation resources); and

• The organization’s rationale for accepting certain weaknesses or deficiencies in the security 

controls.66

Organizational strategies for plans of action and milestones are guided by the security categories 

of the respective information systems affected by the risk mitigation activities. Organizations may 

decide, for example, to allocate the vast majority of risk mitigation resources initially to the 

highest-impact information systems because a failure to correct the weaknesses or deficiencies in 

those systems could potentially have the most significant adverse effects on the organization’s 

missions or business operations. Organizations also prioritize weaknesses or deficiencies using 

information from organizational assessments of risk and the risk management strategy developed 

as part of the risk executive (function). Therefore, a high-impact system would have a prioritized 

list of weaknesses or deficiencies for that system, as would moderate-impact and low-impact

systems. In general, the plan of action and milestones strategy always addresses the highestpriority weaknesses or deficiencies within those prioritized systems.

After completion of the security plan, security assessment report, and plan of action and 

milestones, the information system owner or common control provider submits the final security 

authorization package to the authorizing official or designated representative. Figure F-1 

illustrates the key sections of the authorization package.

FIGURE F-1: SECURITY AUTHORIZATION PACKAGE

F.2 AUTHORIZATION DECISIONS

Authorization decisions are based on the content of the authorization package including inputs 

from the organization’s risk executive (function) and any additional supporting documentation 

required by the authorizing official. The security authorization package provides comprehensive 

information on the security state of the information system. Risk executive (function) inputs, 

including the previously established overarching risk guidance derived from the risk management 

strategy, provide additional information to the authorizing official that may be relevant and affect 

the final authorization decision (e.g., organizational risk tolerance, organization’s overall risk 

mitigation strategy, core mission and business requirements, dependencies among information 

systems, ongoing risk monitoring requirements, and other types of risks not directly associated 

66 Organizations document their rationale for accepting security control weakness or deficiencies.

AUTHORIZING 

OFFICIAL

OR

DESIGNATED

REPRESENTATIVE

• Overview of security requirements, description of 

agreed-upon security controls, and other supporting 

security-related documents.

• Security control assessment results and 

recommended corrective actions for control 

weaknesses or deficiencies.

• Measures planned to correct weaknesses or 

deficiencies and to reduce or eliminate known 

vulnerabilities.

Security Plan

Security

Assessment Report

Plan of Action

and Milestones

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with the information system or its environment of operation). Risk executive (function) inputs are 

documented and become part of the authorization decision. Organizations determine how the risk 

management strategy and risk-related guidance from the risk executive (function) 

influences/impacts the authorization decisions of authorizing officials. Security authorization 

decisions are conveyed to information system owners and common control providers and are 

made available to selected officials within the organization (e.g., information system owners 

inheriting common controls, authorizing officials for interconnected systems, chief information 

officers, senior information security officers, information owners/stewards). There are two types 

of authorization decisions that can be rendered by authorizing officials:

• Authorization to operate;67 and

• Denial of authorization to operate.

Authorization to Operate

If the authorizing official, after reviewing the authorization package and any additional inputs 

provided by the risk executive (function), deems that the risk to organizational operations and 

assets, individuals, other organizations, and the Nation is acceptable, an authorization to operate

is issued for the information system or for the common controls inherited by organizational 

information systems. The information system is authorized to operate for a specified time period 

in accordance with the terms and conditions established by the authorizing official.68 For common 

control providers external to an information system, the authorization decision means that the 

common controls under their control are approved for inheritance by organizational information 

systems. An authorization termination date is also established by the authorizing official as a 

condition of authorization. The authorization termination date can be adjusted by the authorizing 

official to reflect an increased level of concern regarding the security state of the information 

system including the security control employed within or inherited by the system. Authorization 

termination dates do not exceed the maximum allowable time periods for authorization 

established by federal or organizational policy.

The authorizing official takes specific actions to reduce or eliminate vulnerabilities identified 

during the execution of the Risk Management Framework unless the vulnerabilities have been 

explicitly accepted as part of the authorization decision. In addition, the information system 

owner or common control provider establishes a disciplined, structured, and repeatable process to 

monitor the ongoing effectiveness of the deployed security controls and the progress of any 

actions taken to correct or eliminate weaknesses or deficiencies. The plan of action and 

milestones submitted by the information system owner is used by the authorizing official to 

monitor the progress in correcting deficiencies and weaknesses noted during the security control 

assessment.

67 An interim authorization to test is a special type of authorization decision allowing an information system to operate 

in an operational environment for the express purpose of testing the system with actual operational (i.e., live) data for a 

specified time period. An interim authorization to test is granted by an authorizing official only when the operational 

environment or live data is required to complete specific test objectives.

68 Some organizations may choose to use the term interim authorization to operate to focus attention on the increased 

risk being accepted by the authorizing official in situations where there are significant weaknesses or deficiencies in the 

information system, but an overarching mission necessity requires placing the system into operation or continuing its 

operation.

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Denial of Authorization to Operate

If the authorizing official, after reviewing the authorization package and any additional inputs 

provided by the risk executive (function), deems that the risk to organizational operations and 

assets, individuals, other organizations, and the Nation is unacceptable and immediate steps 

cannot be taken to reduce the risk to an acceptable level, a denial of authorization to operate is 

issued for the information system or for the common controls inherited by organizational 

information systems. The information system is not authorized to operate and is not placed into 

operation. If the system is currently in operation, all activity is halted. For common control 

providers external to an information system, the authorization decision means that the common 

controls under their control are not approved for inheritance by organizational information 

systems. Failure to receive an authorization to operate indicates that there are major weaknesses 

or deficiencies in the security controls employed within or inherited by the information system. 

The authorizing official or designated representative works with the information system owner or 

common control provider to revise the plan of action and milestones to ensure that appropriate 

measures are taken to correct the identified weaknesses or deficiencies.

A special case of a denial of authorization to operate is an authorization rescission. Authorizing 

officials can rescind a previous authorization decision at any time in situations where there is a 

specific violation of: (i) federal/organizational security policies, directives, regulations, standards, 

guidance, or practices; or (ii) the terms and conditions of the original authorization. For example, 

failure to maintain an effective continuous monitoring program may be grounds for rescinding an 

authorization decision. Authorizing officials consult with the risk executive (function) and the 

senior information security officer before rescinding security authorizations.

F.3 AUTHORIZATION DECISION DOCUMENT

The authorization decision document transmits the final security authorization decision from the 

authorizing official to the information system owner or common control provider and other key 

organizational officials, as appropriate. The authorization decision document contains the 

following information:

• Authorization decision;

• Terms and conditions for the authorization;

• Authorization termination date; and

• Risk executive (function) input (if provided).

The security authorization decision indicates whether the information system is: (i) authorized to 

operate; or (ii) not authorized to operate. For common controls, the authorization decision means 

that the controls are approved for inheritance by organizational information systems. The terms 

and conditions for the authorization provide a description of any limitations or restrictions placed 

on the operation of the information system or the implementation of common controls that must 

be followed by the system owner or common control provider. The authorization termination 

date, established by the authorizing official, indicates when the security authorization expires and 

reauthorization is required. An authorizing official designated representative prepares the 

authorization decision document for the authorizing official with authorization recommendations, 

as appropriate. The authorization decision document is attached to the original authorization 

package and transmitted to the information system owner or common control provider.69

69 Authorization decision documents may be digitally signed to ensure authenticity.

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Upon receipt of the authorization decision document and authorization package, the information 

system owner or common control provider acknowledges and implements the terms and 

conditions of the authorization and notifies the authorizing official. The information system 

owner or common control provider retains the original authorization decision document and 

authorization package.70 The organization ensures that authorization documents for information 

systems and for common controls are available to appropriate organizational officials (e.g., 

information system owners inheriting common controls, the risk executive [function], chief 

information officers, senior information security officers, information system security officers). 

The contents of the security authorization documentation, especially information regarding 

information system vulnerabilities, are: (i) marked and appropriately protected in accordance with 

federal/organizational policy; and (ii) retained in accordance with the organization’s record 

retention policy. The authorizing official verifies on an ongoing basis, that the terms and 

conditions established as part of the authorization are being followed by the information system 

owner or common control provider.

F.4 ONGOING AUTHORIZATION

A robust and comprehensive continuous monitoring71 strategy integrated into the organization’s 

system development life cycle process, promotes risk management on an ongoing basis and can 

significantly reduce the resources required for reauthorization, if required. Using automation and 

state-of-the-practice tools, techniques, and procedures, risk management can become near realtime with ongoing monitoring of security controls and changes to the information system and its 

environment of operation. When monitoring is conducted in accordance with the needs of the 

authorizing official, that monitoring results in the production of key information needed to 

determine: (i) the current security state of the information system (including the effectiveness of 

the security controls employed within and inherited by the system); (ii) the resulting risks to 

organizational operations, organizational assets, individuals, other organizations, and the Nation; 

and (iii) whether to authorize continued operation of the system or continued use of common 

controls inherited by organizational information systems. Organizations provide an official 

designation (including any approvals required) for information systems that have transitioned 

from initial authorization to operate into an ongoing authorization approach.

Continuous monitoring also helps to amortize the resource expenditures for reauthorization 

activities over the authorization period. The ultimate objective is to achieve a state of ongoing 

authorization where the authorizing official maintains sufficient knowledge of the current 

security state of the information system (including the effectiveness of the security controls 

employed within and inherited by the system) to determine whether continued operation is 

acceptable based on ongoing risk determinations, and if not, which step or steps in the Risk 

Management Framework needs to be re-executed in order to effectively respond to the additional 

risk. Formal reauthorization actions are avoided in situations where the continuous monitoring 

process provides authorizing officials the necessary information to manage the potential risk 

arising from changes to the information system or its environment of operation. Organizations 

maximize the use of status reports and security state information produced during the continuous 

monitoring process to minimize the level of effort required if a formal reauthorization action is 

required.

70 Organizations may choose to employ automated tools to support the development, distribution, and archiving of risk 

management documentation to include artifacts associated with the security authorization process.

71 Continuous monitoring is described in Appendix G. NIST Special Publication 800-137 provides additional guidance 

for Information Security Continuous Monitoring Programs.

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When an information system is under ongoing authorization, the system may be authorized for 

ongoing operation on a time-driven or event-driven basis, leveraging the security-related 

information generated by the continuous monitoring program. The system is reviewed and 

authorized for ongoing operation on a time-driven basis in accordance with the authorization 

frequency determined as part of the continuous monitoring strategy. The system is reviewed and 

authorized for ongoing operation on an event-driven basis when pre-defined (trigger) events 

occur or at the discretion of the authorizing official. Whether the authorization for ongoing 

operation is time-driven or event-driven, the authorizing official acknowledges ongoing 

acceptance of identified risks. The organization determines the level of formality required for

such acknowledgement by the authorizing official.

F.5 REAUTHORIZATION

Formal reauthorization actions occur at the discretion of the authorizing official in accordance 

with federal or organizational policy. If a formal reauthorization action is required, organizations 

maximize the use of security and risk-related information produced as part of the continuous 

monitoring processes currently in effect. Formal reauthorization actions, if initiated, can be either 

time-driven or event-driven. Time-driven reauthorizations occur when the authorization 

termination date is reached (if one is specified). If the information system is under ongoing 

authorization (i.e., a continuous monitoring program is in place that monitors all implemented 

common, hybrid, and system-specific controls with the frequency specified in the continuous 

monitoring strategy), time-driven reauthorizations may not be necessary. However, if the 

continuous monitoring program is not yet comprehensive enough to fully support ongoing 

authorization, a maximum authorization period can be specified by the authorizing official.

Authorization termination dates are influenced by federal and/or organizational policies and by 

the requirements of authorizing officials which may establish maximum authorization periods.

For security control assessments associated with reauthorization, organizations leverage securityrelated information generated by the existing continuous monitoring program and fill in any gaps 

with manual or procedural assessments. Organizations may also supplement automaticallygenerated information with manually/procedurally-generated assessment information in situations 

where greater assurance is needed. If the security control assessments are conducted by qualified 

assessors with the required degree of independence based on federal/organizational policies, 

appropriate security standards and guidelines, and the needs of the authorizing official, the 

assessment results can be cumulatively applied to the reauthorization.

72 The reauthorization action 

can be as simple as updating the security status information in the authorization package (i.e., the 

security plan, security assessment report, and plan of action and milestones). The authorizing 

official subsequently signs an updated authorization decision document based on the current 

determination and acceptance of risk to organizational operations and assets, individuals, other 

organizations, and the Nation.73

In the event that there is a change in authorizing officials, the new authorizing official reviews the 

current authorization decision document, authorization package, and any updated documents 

created as a result of the ongoing monitoring activities. If the new authorizing official is willing 

to accept the currently documented risk, then the official signs a new authorization decision 

document, thus formally transferring responsibility and accountability for the information system 

72 NIST Special Publication 800-53A describes the specific conditions when security-related information can be reused 

in security authorizations, ongoing authorizations, and reauthorizations.

73 Decisions to initiate a formal reauthorization action include inputs from the risk executive (function) and the senior 

information security officer.

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or the common controls inherited by organizational information systems and explicitly accepting 

the risk to organizational operations and assets, individuals, other organizations, and the Nation. 

If the new authorizing official is not willing to accept the previous authorization results (including 

identified level of risk), a reauthorization action may need to be initiated or the new authorizing 

official may instead establish new terms and conditions for continuing the original authorization, 

but not extend the original authorization termination date. In all situations where there is a 

decision to reauthorize an information system or the common controls inherited by organizational 

information systems, the maximum reuse of authorization information is strongly encouraged to 

minimize the time and expense associated with the reauthorization effort.74

F.6 EVENT-DRIVEN TRIGGERS

Organizations may define event-driven triggers (i.e., indicators and/or prompts that cause a predefined organizational reaction) for both ongoing authorization and reauthorization. Event-driven 

triggers include, but are not limited to: (i) new threat/vulnerability/impact information; (ii) an 

increased number of findings, weaknesses, and/or deficiencies from the continuous monitoring 

program; (iii) new missions/business requirements; (iv) a change in the Authorizing Official; (v) 

a significant change in risk assessment findings; (vi) significant changes to the information 

system, common controls, or the environment of operation; or (vii) organizational thresholds 

being exceeded.

A significant change is defined as a change that is likely to affect the security state of an 

information system. Significant changes to an information system may include for example: (i) 

installation of a new or upgraded operating system, middleware component, or application; (ii) 

modifications to system ports, protocols, or services; (iii) installation of a new or upgraded 

hardware platform; (iv) modifications to cryptographic modules or services; or (v) modifications 

to security controls. Examples of significant changes to the environment of operation may include 

for example: (i) moving to a new facility; (ii) adding new core missions or business functions; 

(iii) acquiring specific and credible threat information that the organization is being targeted by a 

threat source; or (iv) establishing new/modified laws, directives, policies, or regulations.75

If a formal reauthorization action is initiated, the organization targets only the specific security 

controls affected by the changes and reuses previous assessment results wherever possible. Most 

routine changes to an information system or its environment of operation can be handled by the 

organization’s continuous monitoring program, thus supporting the concept of ongoing 

authorization. An effective monitoring program can significantly reduce the overall cost and level 

of effort of reauthorization actions.

F.7 TYPE AUTHORIZATION

A type authorization76 is an official authorization decision to employ identical copies of an 

information system or subsystem (including hardware, software, firmware, and/or applications) in 

74 The decision to initiate a formal reauthorization action can be based on a variety of factors, including for example, 

the acceptability of the previous authorization information provided in the authorization package, the length of time 

since the previous authorization decision, the risk tolerance of the new authorizing official, and current organizational 

requirements and/or priorities.

75 The examples of changes listed above are only significant when they meet the threshold established in the definition 

of significant change (i.e., a change that is likely to affect the security state of the information system).

76 Examples of type authorizations include: (i) an authorization of the hardware and software applications for a standard 

financial system deployed in several locations around the world; or (ii) an authorization of a common workstation or 

operating environment (i.e., hardware, operating system, middleware, and applications) deployed to all operating units 

within an organization.

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specified environments of operation. This form of authorization allows a single authorization 

package (i.e., security plan, security assessment report, and plan of action and milestones) to be 

developed for an archetype (common) version of an information system that is deployed to 

multiple locations, along with a set of installation and configuration requirements or operational 

security needs, that will be assumed by the hosting organization at a specific location. The type 

authorization is used in conjunction with the authorization of site-specific controls (e.g., physical 

and environmental protection controls, personnel security controls) inherited by the information 

system.77 The RMF tasks listed in Chapter 3 address the authorization activities associated with 

the employment of system-specific, hybrid, and common controls.

F.8 AUTHORIZATION APPROACHES

Organizations can choose from three different approaches when planning for and conducting 

security authorizations to include: (i) an authorization with a single authorizing official; (ii) an 

authorization with multiple authorizing officials; or (iii) leveraging an existing authorization.78 

The first approach is the traditional authorization process defined in this appendix where a single 

organizational official in a senior leadership position is both responsible and accountable for an 

information system. The organizational official also accepts the information system-related 

security risks that may impact organizational operations and assets, individuals, other 

organizations, or the Nation.

The second approach, or joint authorization, is employed when multiple organizational officials 

either from the same organization or different organizations, have a shared interest in authorizing 

an information system. The organizational officials collectively are responsible and accountable 

for the information system and jointly accept the information system-related security risks that 

may adversely impact organizational operations and assets, individuals, other organizations, and 

the Nation. A similar authorization process is followed as in the first approach with the essential 

difference being the addition of multiple authorizing officials. Organizations choosing a joint 

authorization approach are expected to work together on the planning and the execution of RMF 

tasks (see Appendix H) and to document their agreement and progress in implementing the tasks. 

Collaborating on the security categorization, selection of security controls, plan for assessing the 

controls to determine effectiveness, plan of action and milestones, and continuous monitoring 

strategy, is necessary for a successful joint authorization. The specific terms and conditions of the 

joint authorization are established by the participating parties in the joint authorization including 

for example, the process for ongoing determination and acceptance of risk. The joint 

authorization remains in effect only as long as there is mutual agreement among authorizing 

officials and the authorization meets the requirements established by federal and/or organizational 

policies.

The final approach, leveraged authorization, is employed when a federal agency79 chooses to 

accept some or all of the information in an existing authorization package generated by another 

federal agency (hereafter referred to as the owning organization80) based on a need to use the 

77 Site-specific controls are typically implemented by an organization as common controls.

78 Authorization approaches can be applied to both information systems and to common controls inherited by one or 

more organizational information systems.

79 In this situation, federal agency includes any organizations that are subordinate to the agency. For example, NIST is a 

subordinate organization to the Department of Commerce.

80 The term owning organization refers to the federal agency or subordinate organization that owns the authorization 

package. The information system may not be owned by the same organization that owns the authorization package, for 

example, in situations where the system/services are provided by an external provider.

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same information resources (e.g., information system and/or services provided by the system). 

The leveraging organization reviews the owning organization’s authorization package as the basis 

for determining risk to the leveraging organization.81 When reviewing the authorization package, 

the leveraging organization considers risk factors such as the time elapsed since the authorization 

results were produced, the environment of operation (if different from the environment of 

operation reflected in the authorization package), the criticality/sensitivity of the information to 

be processed, stored, or transmitted, as well as the overall risk tolerance of the leveraging 

organization. If the leveraging organization determines that there is insufficient information in the 

authorization package or inadequate security measures in place for establishing an acceptable 

level of risk, the leveraging organization may negotiate with the owning organization for 

additional security measures and/or security-related information.82 Additional security measures 

may include, for example, increasing the number of security controls, conducting additional 

assessments, implementing compensating controls, or establishing constraints on the use of the 

information system or services provided by the system. Security-related information may include, 

for example, other information that the owning organization may have discerned in the use or 

assessment of the information system that is not reflected in the authorization package. The 

additional security measures and/or security-related information may be provided by the 

leveraging organization, the information system developer, some other external third party, or 

some combination of the above.

The leveraged authorization approach provides opportunities for significant cost savings and 

avoids a potentially costly and time-consuming authorization process by the leveraging 

organization. Leveraging organizations generate an authorization decision document and 

reference, as appropriate, information in the authorization package from the owning organization. 

In situations where addition security measures are implemented, the leveraging organization 

documents those measures by creating an addendum to the original authorization package of the 

owning organization. This addendum may include, as appropriate, updates to the security plan, 

security assessment report, and/or plan of action and milestones. Consistent with the traditional 

authorization process described above, a single organizational official in a senior leadership 

position in the leveraging organization is both responsible and accountable for accepting the 

information system-related security risks that may impact the leveraging organization’s 

operations and assets, individuals, other organizations, or the Nation. The leveraged authorization 

remains in effect as long as the leveraging organization accepts the information system-related 

security risks and the authorization meets the requirements established by federal and/or 

organizational policies. This requires the sharing of information resulting from continuous 

monitoring activities conducted by the owning organization (e.g., updates to the security plan, 

security assessment report, plan of action and milestones, and security status reports). To enhance 

the security of all parties, the leveraging organization can also share with the owning 

organization, the results from any RMF-related activities it conducts to supplement the 

authorization results produced by the owning organization.

For all three authorization approaches described above, risk management-related activities 

(including RMF tasks) involving external providers are carried out in accordance with the 

guidance provided in Appendices H and I.

81 The sharing of the authorization package (including the security plan, security assessment report, plan of action and 

milestones, and authorization decision document) is accomplished under terms and conditions agreed upon by all 

parties (i.e., the owning organization and the leveraging organization).

82 Negotiations with the owning organization may include other organizations (e.g., when the information system 

and/or services are provided to the owning organization in full or in part, by an external provider).

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APPENDIX G

CONTINUOUS MONITORING

MANAGING AND TRACKING THE SECURITY STATE OF INFORMATION SYSTEMS

critical aspect of managing risk to information from the operation and use of information 

systems involves the continuous monitoring of the security controls employed within or 

inherited by the system.83 Conducting a thorough point-in-time assessment of the 

deployed security controls is a necessary but not sufficient condition to demonstrate security due 

diligence. An effective organizational information security program also includes a rigorous 

continuous monitoring program integrated into the system development life cycle. The objective 

of the continuous monitoring program is to determine if the set of deployed security controls 

continue to be effective over time in light of the inevitable changes that occur. A well-designed 

and well-managed continuous monitoring program can effectively transform an otherwise static 

security control assessment and risk determination process into a dynamic process that provides 

essential, near real-time security status-related information to organizational officials in order to 

take appropriate risk mitigation actions and make cost-effective, risk-based decisions regarding 

the operation of the information system. Continuous monitoring programs provide organizations 

with an effective mechanism to update security plans, security assessment reports, and plans of 

action and milestones. The following sections provide a general overview of some fundamental 

concepts associated with continuous monitoring. NIST Special Publication 800-137 provides 

additional guidance on the development and implementation of information security continuous 

monitoring programs.

G.1 MONITORING STRATEGY

Organizations develop a strategy and implement a program for the continuous monitoring of 

security control effectiveness. The monitoring program is integrated into the organization’s 

system development life cycle processes. A robust continuous monitoring program requires the 

active involvement of information system owners and common control providers, chief 

information officers, senior information security officers, and authorizing officials. The 

monitoring program allows an organization to: (i) track the security state of an information 

system on a continuous basis; and (ii) maintain the security authorization for the system over time 

in highly dynamic environments of operation with changing threats, vulnerabilities, technologies, 

and missions/business processes.

Continuous monitoring of security controls using automated support tools facilitates near realtime risk management and represents a significant change in the way security authorization 

activities have been employed in the past. Near real-time risk management of information 

systems can be facilitated by employing automated support tools to execute various steps in the 

RMF including authorization-related activities. In addition to vulnerability scanning tools, system 

and network monitoring tools, and other automated support tools that can help to determine the 

security state of an information system, organizations can employ automated security 

management and reporting tools to update key documents in the authorization package including 

the security plan, security assessment report, and plan of action and milestones. The documents in 

the authorization package are considered “living documents” and updated accordingly based on 

actual events that may affect the security state of the information system.

83 A continuous monitoring program within an organization involves a different set of activities than Security Incident 

Monitoring or Security Event Monitoring programs.

A

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Timeliness is critical for near-real time risk management. Organizations are encouraged to 

consolidate available information into measures that can be displayed as trend reports or other 

types of dashboard visualization to assist decision makers with timely review and decision 

making. Transitioning to a near real-time risk management environment requires the increased 

use of automated support tools over time as organizations integrate these technologies into their 

information security programs in accordance with available resources.

An effective organization-wide continuous monitoring program84 includes:

• Defining a continuous monitoring strategy based on risk tolerance that maintains clear 

visibility into assets, awareness of vulnerabilities, up-to-date threat information, and 

mission/business impacts;

• Establishing and implementing a continuous monitoring program that includes monitoring all 

implemented controls at the organization-defined frequency;

85

• Analyzing and reporting findings to appropriate organizational officials;

86

• Responding to findings with mitigation, acceptance, transference/sharing, or 

avoidance/rejection; and

• Reviewing and updating the continuous monitoring strategy and program to increase 

visibility into assets and awareness of vulnerabilities.

Continuous monitoring is a tactic in a larger strategy of organization-wide risk management. 

Organizations increase situational awareness through enhanced monitoring capabilities and 

subsequently increase insight into and control of the processes used to manage organizational 

security.

G.2 FREQUENCY OF SECURITY CONTROL MONITORING

The criteria for determining the frequency of security control monitoring is established by the 

information system owner or common control provider in collaboration with the authorizing 

official or designated representative, chief information officer, senior information security officer, 

and risk executive (function). The frequency criteria reflects the organization’s priorities and 

importance of the information system (or in the case of common controls, the information 

systems inheriting the controls) to organizational operations and assets, individuals, other 

organizations, and the Nation in accordance with FIPS 199 or CNSS Instruction 1253. 

Organizations may use recent risk assessments (including current threat and vulnerability 

information), history of cyber attacks, results of previous security assessments, and operational 

requirements in guiding the frequency of security control monitoring.

84 Although the primary focus of continuous monitoring activities is on the effectiveness of security controls employed 

within and inherited by an information system, there are other equally important external factors in the environment of 

operation for a system that also require monitoring on an ongoing basis. These factors include, for example, changes in 

the organization’s missions or business processes, changes in the threat space, and changes in tolerance for previously 

accepted risks.

85 Through the use of automation, it is possible to monitor a greater number of security controls on an ongoing basis

than is feasible using manual processes. As a result, organizations may choose to monitor a greater number of security 

controls with increased frequency.

86 Organizations have significant latitude and flexibility in the breadth, depth, and formality of security status reports. 

At a minimum, security status reports describe or summarize key changes to security plans, security assessment reports, 

and plans of action and milestones. At the discretion of the organization, security status reports on information systems 

can be used to help satisfy the FISMA reporting requirement for documenting remedial actions on any security-related 

weaknesses or deficiencies.

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While a comprehensive discussion of considerations for determining monitoring frequencies is 

provided in NIST Special Publication 800-137, it is important to note that security controls that 

have the greatest volatility and the controls that have been identified in the organization’s plan of 

action and milestones are typically monitored more frequently. Security control volatility is a 

measure of how frequently a control is likely to change over time subsequent to its 

implementation. For example, security policies and procedures in a particular organization may 

not be likely to change from one year to the next and thus would likely be security controls with 

lower volatility. Access controls or other (technical) security controls that are subject to the direct 

effects or side effects of frequent changes in hardware, software, and/or firmware components of 

an information system would likely be controls with higher volatility and therefore, require more 

frequent monitoring. Security controls identified in the plan of action and milestones are also a 

priority in the continuous monitoring process, due to the fact that these controls have been 

deemed to be ineffective to some degree. Such controls may also require more frequent 

monitoring. The authorizing official or designated representative approves the set of security 

controls that are to be monitored on an ongoing basis as well as the frequency of the monitoring 

activities.

G.3 KEY DOCUMENT UPDATES AND STATUS REPORTING

Continuous monitoring results are considered with respect to any necessary updates to the 

security plan, security assessment report, and plan of action and milestones, since these 

documents are used to guide future risk management activities. Updated security plans reflect any 

modifications to security controls based on the risk mitigation activities carried out by 

information system owners or common control providers. Updated security assessment reports 

reflect additional assessment activities conducted by assessors to determine security control 

effectiveness based on modifications to the security plan and deployed controls. Updated plans of 

action and milestones: (i) report progress made on the current outstanding items listed in the plan; 

(ii) address vulnerabilities discovered during the security impact analysis or security control 

monitoring; and (iii) describe how the information system owner or common control provider 

intends to address those vulnerabilities. The results of monitoring activities are reported to 

authorizing officials on an ongoing basis in the form of status reports. Other key organizational 

officials (e.g., risk executive [function], senior information security officer) receive the results of

continuous monitoring activities as needed or as requested. With the use of automated support 

tools and effective organization-wide security program management practices, authorizing 

officials have the capability to access the most recent documentation in the authorization package 

at any time to determine the current security state of the information system, to help manage risk, 

and to provide essential information for potential reauthorization decisions. The monitoring of 

security controls and changes to the information system and its environment of operation, 

continues throughout the system development life cycle. Summaries of monitoring results are 

provided to the senior information security officer and the risk executive (function).

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APPENDIX H

OPERATIONAL SCENARIOS

APPLYING THE RISK MANAGEMENT FRAMEWORK IN DIFFERENT ENVIRONMENTS

anaging risk to information from the operation and use of information systems in 

modern computing environments with a diverse set of potential business relationships 

can be challenging for organizations. Relationships are established and maintained in a 

variety of ways, for example, through joint ventures, business partnerships, outsourcing 

arrangements (i.e., through contracts, lines of business arrangements, interagency and intraagency agreements), licensing agreements, and supply chain arrangements.87 The Risk 

Management Framework (RMF) applies only to federal information systems. There are two 

distinct types of operational scenarios that affect how organizations address the RMF steps and 

associated tasks:

• Information systems used or operated by federal agencies;

88 and

• Information systems used or operated by other organizations89on behalf of federal agencies.

SCENARIO 1: For an information system that is used or operated by a federal agency, the system 

boundary is defined by the agency. The agency conducts all RMF tasks to include information 

system authorization. The agency maintains control over the security controls employed within 

and inherited by the information system.

SCENARIO 2: For an information system that is used or operated by another organization on 

behalf of a federal agency, the system boundary is defined by the agency in collaboration with the 

other organization and one of the following situations applies:

- If the organization is contracted to a federal agency, the contractor can conduct all RMF tasks 

except those tasks which must be carried out by the federal agency as part of its inherent 

governmental responsibilities.90 The agency provides RMF-related inputs to the contractor, as 

needed, and maintains strict oversight on all contractor-executed RMF tasks. The contractor 

provides appropriate evidence in the security authorization package for the authorization 

decision by the authorizing official from the federal agency.

- If the organization is a federal agency, the organization can conduct all RMF tasks to include 

the information system authorization. The information system authorization can also be a joint 

authorization if both parties agree to share the authorization responsibilities. In situations 

where a federal agency uses or operates an information system on behalf of multiple federal 

agencies, the joint authorization can include all participating agencies.

87 NIST Special Publication 800-53 provides additional guidance on the application and use of security controls in 

external environments to include relationships with external service providers.

88 References to federal agencies include organizations that are subordinate to those agencies.

89 Organizations that use or operate an information system on behalf of a federal agency or one of its subordinate 

organizations can include, for example, other federal agencies or their subordinate organizations, state and local 

government agencies, contractors, and academic institutions.

90 Organizations ensure that requirements for conducting the specific tasks in the RMF are included in appropriate 

contractual vehicles, including requirements for independent assessments, when appropriate.

M

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APPENDIX I

SECURITY CONTROLS IN EXTERNAL ENVIRONMENTS

PARTNERSHIPS, OUTSOURCING, AND SUPPLY CHAIN CONSIDERATIONS

rganizations are becoming increasingly reliant on information system services provided 

by external providers to carry out important missions and business functions. External 

information system services are services implemented outside of the authorization 

boundaries established by the organization for its information systems. These external services 

may be used by, but are not part of, organizational information systems. In some situations, 

external information system services may completely replace the functionality of internal 

information systems. Organizations are responsible and accountable for the risk incurred by use 

of services provided by external providers and address this risk by implementing compensating 

controls when the risk is greater than the authorizing official or the organization is willing to 

accept.

Relationships with external service providers are established in a variety of ways, for example, 

through joint ventures, business partnerships, outsourcing arrangements (i.e., through contracts, 

interagency agreements, lines of business arrangements), licensing agreements, and/or supply 

chain exchanges. The growing dependence on external service providers and new relationships 

being forged with those providers present new and difficult challenges for the organization, 

especially in the area of information system security. These challenges include:

• Defining the types of external services provided to the organization;

• Describing how the external services are protected in accordance with the security 

requirements of the organization; and

• Obtaining the necessary assurances that the risk to organizational operations and assets, 

individuals, other organizations, and the Nation arising from the use of the external services 

is acceptable.

FISMA and OMB policy require external providers handling federal information or operating 

information systems on behalf of the federal government to meet the same security requirements 

as federal agencies. Security requirements for external providers including the security controls 

for information systems processing, storing, or transmitting federal information are expressed in 

appropriate contracts or other formal agreements. Organizations can require external providers to 

implement all steps in the RMF with the exception of the security authorization step, which 

remains an inherent federal responsibility that is directly linked to the management of risk related 

to the use of external information system services.91

The assurance or confidence that the risk from using external services is at an acceptable level 

depends on the trust92 that the organization places in the external service provider. In some cases, 

the level of trust is based on the amount of direct control the organization is able to exert on the 

91 If the external provider is a federal agency, the provider can conduct all RMF tasks to include the information system 

authorization (see Appendix H).

92 The level of trust that an organization places in an external service provider can vary widely, ranging from those who 

are highly trusted (e.g., business partners in a joint venture that share a common business model and common goals) to 

those who are less trusted and represent greater sources of risk (e.g., business partners in one endeavor who are also 

competitors in another market sector).

O

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external service provider with regard to employment of security controls necessary for the 

protection of the service and the evidence brought forth as to the effectiveness of those controls. 

The level of control is usually established by the terms and conditions of the contract or servicelevel agreement with the external service provider and can range from extensive (e.g., negotiating 

a contract or agreement that specifies detailed security control requirements for the provider) to 

very limited (e.g., using a contract or service-level agreement to obtain commodity services93

such as commercial telecommunications services). In other cases, the level of trust is based on 

factors that convince the organization that the requisite security controls have been employed and 

that a determination of control effectiveness exists. For example, a separately authorized external 

information system service provided to an organization through a well-established line of 

business relationship may provide a degree of trust in the external service within the tolerable risk 

range of the authorizing official.

The provision of services by external providers may result in some services without explicit 

agreements between the organization and the external entities responsible for the services.

Whenever explicit agreements are feasible and practical (e.g., through contracts, service-level 

agreements, etc.), the organization develops such agreements and requires the use of the security 

controls in NIST Special Publication 800-53. When the organization is not in a position to require 

explicit agreements with external providers (e.g., the service is imposed on the organization or the 

service is commodity service), the organization establishes explicit assumptions about the service 

capabilities with regard to security. In situations where an organization is procuring information 

system services or technologies through a centralized acquisition vehicle (e.g., government-wide 

contract by the General Services Administration or other preferred and/or mandatory acquisition 

organization), it may be more efficient and cost-effective for the originator of the contract to 

establish and maintain a stated level of trust with the external provider (including the definition of 

required security controls and level of assurance with regard to the provision of such controls). 

Organizations subsequently acquiring information system services or technologies from the 

centralized contract can take advantage of the negotiated trust level established by the 

procurement originator and thus avoid costly repetition of the activities necessary to establish 

such trust.94 Contracts and agreements between the organization and external providers may also

require the active participation of the organization. For example, the organization may be 

required by the contract to install public key encryption-enabled client software recommended by 

the service provider.

Ultimately, the responsibility for adequately mitigating unacceptable risks arising from the use of 

external information system services remains with the authorizing official. Organizations require 

that an appropriate chain of trust be established with external service providers when dealing with 

the many issues associated with information system security. A chain of trust requires that the 

organization establish and retain a level of confidence that each participating service provider in 

the potentially complex consumer-provider relationship provides adequate protection for the 

services rendered to the organization. The chain of trust can be complicated due to the number of 

93 Commercial providers of commodity-type services typically organize their business models and services around the 

concept of shared resources and devices for a broad and diverse customer base. Therefore, unless organizations obtain 

fully dedicated services from commercial service providers, there may be a need for greater reliance on compensating 

security controls to provide the necessary protections for the information system that relies on those external services. 

The organization’s risk assessment and risk mitigation activities reflect this situation.

94 For example, a procurement originator could authorize an information system providing external services to the 

federal government under specific terms and conditions of the contract. A federal agency requesting information 

system services under the terms of the contract would not be required to reauthorize the information system when 

acquiring such services (unless the request included services outside the scope of the original contract).

APPENDIX I PAGE I-2

 
Special Publication 800-37 Guide for Applying the Risk Management Framework to Federal Information Systems

Revision 1 A Security Life Cycle Approach

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entities participating in the consumer-provider relationship and the type of relationship between 

the parties. External service providers may also in turn outsource the services to other external 

entities, making the chain of trust even more complicated and difficult to manage. Depending on 

the nature of the service, it may simply be unwise for the organization to place significant trust in 

the provider—not due to any inherent untrustworthiness on the provider's part, but due to the 

intrinsic level of risk in the service. Where a sufficient level of trust cannot be established in the 

external services and/or service providers, the organization: (i) employs compensating controls; 

(ii) accepts a greater degree of risk; or (iii) does not obtain the service (i.e., performs missions or 

business operations with reduced levels of functionality or possibly no functionality at all).

APPENDIX I PAGE I-3